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Capillary Electrophoresis in Global Emerging Markets: A Regulatory Perspective Brian K. Nunnally, Ph.D.

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Page 1: Capillary Electrophoresis in Global Emerging Markets: …c.ymcdn.com/sites/casss.site-ym.com/resource/resmgr/CE_Pharm...manufacturing process, ... From ASEAN Guideline on Analytical

Capillary Electrophoresis in Global

Emerging Markets A Regulatory

Perspective

Brian K Nunnally PhD

Agenda

The Lifecycle Approach ndash a guidance review

What it really meanshellip

Global Emerging Markets and their impact on the CE

professional

Selected questions and their answers

Lifecycle management guidance

Health Canada published one in 2004 (GUI-0029)

It was revised in 2009

The activities relating to validation studies may be

classified into three phases

- Phase 1 Pre-Validation Phase or the Qualification Phase

- Phase 2 Process Validation Phase (Process Qualification

phase)

- Phase 3 Validation Maintenance Phase

Other recent guidances have been published by FDA

and EMA (draft)

The guidance is specific to Process Validation however it can be

applied to analytical as well

Process Validation Guidance from FDA (2011)

The guidance aligns process validation activities with the

product lifecycle concept and with existing FDA

guidance

The lifecycle concept links product and process

development qualification of the commercial

manufacturing process and maintenance of the process

in a state of control during routine commercial

production

The concept aligns with expectations for the analytical

validation and ongoing laboratory data generation

FDA Guidance Process validation stages

Stage 1 ndash Process Design development and scale-up

activities

Stage 2 ndash Process Qualification Proof of reproducible

commercial manufacturing

Stage 3 ndash Continued Process Verification Ongoing

assurance of process control

FDA Guidance Process validation stages ndash

applied to the analytical laboratory

Stage 1 ndash Analytical Method Design development and

initial qualification activities

Stage 2 ndash Analytical Method Qualification Proof of

reproducible commercial testing

Stage 3 ndash Continued Analytical Method Verification

Ongoing assurance of analytical control

Expectations of the CE professional

Understand the sources of variation

Detect the presence and degree of variation

Understand the impact of variation on the process and

ultimately on product attributes

Control the variation in a manner commensurate with the

risk it represents to the process and product

Understanding variability

Variability comes in three

forms process sample

and analytical

A control chart of the lot

release values will

encompass all three forms

of variability

It is rare that all three types

can be accurately

quantitated without a

carefully planned and

executed hierarchical or

similar study

σsup2 = σsup2P + σsup2S + σsup2T

Where

σsup2 = Total variance

σsup2P = Process variance

σsup2S = Sampling variance

σsup2T = Test variance

Illustrating Stability

0

2

4

6

8

10

12

14

0 5 10 15 20 25 30 35 40 45 50

If the points fall at random about the centreline

and remain within the control limits the

process is deemed to be stable

Illustrating Instability

0

2

4

6

8

10

12

14

16

18

20

0 5 10 15 20 25 30 35 40 45 50

If this red line is the test specification

should we react to the ldquospecial causerdquo

A better way

0

2

4

6

8

10

12

14

16

18

20

0 5 10 15 20 25 30 35 40 45 500

2

4

6

8

10

12

14

16

18

20

0 5 10 15 20 25 30 35 40 45 50

Re-drawing the limits makes it easy to see

17

18

19

20

21

22

23

24

25

26

27

1 4 7 10 13 16 19 22 25 28 31 34 37 40 43

15

17

19

21

23

25

27

29

31

33

35

1 4 7 10

13

16

19

22

25

28

31

34

37

40

43

Production Data Laboratory Controls

Where Lies The Problem Limits are set as per the usual practice plusmn 3 sigma

Understanding the data

18

19

20

21

22

23

24

25

26

0 5 10 15 20 25 30 35 40 45 50

1-P

oint

Ave

rage

0

05

1

15

2

25

3

35

4

45

5

Ran

ge

20

22

24

26

28

30

32

34

0 5 10 15 20 25 30 35 40 45 50

1-P

oint

Ave

rage

0

2

4

6

8

10

12

Ran

ge

Understanding the data

Shewhart Control Charts are Usedhellip

Global Emerging Markets

For most life cycle management activites focus on the

ldquoreferencerdquo markets eg US EMA Canada Japan

There are of course hundreds of other markets

The prominent and fast growing are referred to as Global

Emerging Markets

These markets are becoming strategically important for

the pharmaceutical industry

Global Emerging Markets

Country IMFNext-

11BRICCIVETS FTSE MSCI

THE

ECONOMI

ST

SampPDOW

JONESBBVA

Columbia

University

EMGP

Argentina

Bahrain

Bangladesh

Brazil

Chile

China

Colombia

Egypt

Hong Kong

India

Indonesia

Israel

Jordan

Kuwait

Malaysia

Mauritius

Mexico

Morocco

Nigeria

Global Emerging Markets

Country IMFNext-

11BRICCIVETS FTSE MSCI

THE

ECONOMI

ST

SampPDOW

JONESBBVA

Columbia

University

EMGP

Oman

Pakistan

Peru

Philippines

Qatar

Russia

Saudi Arabia

Singapore

South Africa

South Korea

Sri Lanka

Taiwan

Thailand

Tunisia

Turkey

UAE

Ukraine

Venezuela

Vietnam

Characteristics of GEM Regulatory Agencies

Many markets expect a major market (eg US or EMA)

approval before filing

- This facilitates approval in these countries

- Notable exceptions South Africa Brazil

Requirements and expertise can vary widely but both

are increasing

- Example Azerbaijan vs Russia vs India

- Example HSA (Singapore)

GEM Challenges

Regulations are evolving

- Advances ICH Pharmaceutical Inspection Coop Scheme

Regulations and guidelines (along with unstated

expectations) are not globally harmonized - Many country or region-specific requirements and interpretation of

guidance

- Pharmacopeia standards differ country to country

- GMPs are not globally harmonized

- Inspections are not globally harmonized

- Differences exist for reviewapproval times clinical trial application

content specification

- Approval of changes is not harmonized

- Post approval reporting requirements are not harmonized

18

GEM Challenges

Increasing complexity with foreign countries

bull Language time zones culture FMAs in-country testing

availability of instrumentation technical savvy

New requirements for some GEM countries

IP issues

Inspections

Multiple approved dossier versions for a single drug

- Multiple specifications multiple item codes different CoAs

different responses to questions

Overall Global CTD not possible

Understanding both the intent and expectations of

questions

19

In-country testing

Many countries require in country testing either before

approval or after launch of the product

Capillary electrophoresis (among other methodologies)

can be a challenge for some markets

Methods need to be robust () to facilitate transfer to

these markets

In-country testing (example)

Country Mandatory Requirement

Small Molecules Biologicals

Full vs Partial testing Local vs Contract Lab

Argentina Yes Yes Full Local Lab mandated

Brazil Yes NA Full Local Lab mandated

Chile Yes Yes Partial is possible Can be contracted out

Uruguay Yes Yes Theoretically full testing selected possible Can be contracted out

Mexico Yes Yes Full Testing (for n=20 batches) Then request a

reduction If tests are too expensive or require

sophisticated equipment reduction is possible

Testing is exempted for orphan drugs

Can be contracted out

Russia Yes Yes Full testing for new registrations Laboratory assigned by

MoH

Turkey Yes Yes Tests performed are based on the product but

normally these include Biological Dissolution

Physical physicochemical controls Content

uniformity amount Microbiological purity and ID

Official analysis institution

of TMOH

Ukraine Yes Yes Full testing State local laboratory

assigned by the MoH

Israel Yes Yes Full testing for the first imported batch and then

upon MoH request

Testing carried out by

MOH Lab

Other countries requiring testing Costa Rica DR El Salvador Ecuador Guatemala Honduras

Nicaragua Panama South Korea etc

GEM Requirements (examples) Brazil (Resolution RDC No 17 16 Apr 2010)

Article 19 Qualification and validation should not be considered only

exercises After the adoption of the qualification andor validation

report it there should have a continuous monitoring program which

must be based on periodic review [Note software validation and re-

validation is called out as a specific self-inspection item]

Article 209 Sole Paragraph Compendial analytical methods do not

require validation but before its implementation there must be

documented evidence of their suitability in the laboratory operating

conditions

Article 312 sect 3 The pharmacopoeial methods should be used for the

validation and performance of the sterility test

Article 463 sect 2 The retrospective validation is no longer encouraged

and is not applicable to the manufacture of sterile products

Article 479 sect 2 A risk assessment should be used to determine the

scope and extent of validation 22

GEM Requirements (examples) Thailand (QampA on ASEAN Analytical Validation)

6 Identify the conditionsscenarios when each of the following is

required to be conducted Full validation Revalidation Verification

Refer to 1 for Full validation and Verification According to ASEAN

Guideline revalidation may be required in the following circumstances

- Change in the synthesis of the drug substance

- Change in the composition of the finished product

- Change in the analytical procedure

From ASEAN Guideline on Analytical Validation (consistent with ICH)

The compendial methods are not required to be validated but merely

verify their suitability under actual conditions of use

23

GEM Requirements (examples) ASEAN Variation Guideline for Pharmaceutical

Products

Major Variation

- No analytical examples (not counting specification changes)

Minor Variation - Prior Approval (MiV-PA)

- Change of test procedure to non-compendial drug substance (must at

least show equivalence to former procedure) ndash MiV-PA9

- Change of in-process controls applied during the manufacture of the drug

substance (including tightening and addition of new in-process test) ndash MiV-

PA6

- Change of in-process controls applied during the manufacture of the drug

product (including tightening and addition of new in-process test) ndash MiV-

PA19

bull Interesting note Any new test method does not concern a novel non-standard

technique or a standard technique used in a novel way

Minor Variation - Notification (MiV-N)

- No analytical examples

24

GEM Requirements (examples) South Africa (Amendments)

Four categories

- Type A - amendments that may be implemented without intervention of or prior

notification to Council

- Type B - amendments that require prior notification

- Type C - amendments that require prior approval

- Type D - amendments that should be considered new applications

Type A Biological examples

- (25) Addition of release tests and or of specifications or tightening of

specifications for intermediates of the APIs

Type B Biological examples

- No analytical examples

25

GEM Requirements (examples) South Africa (Amendments)

Type C Biological examples

- (19B) Any change in analytical methods that

bull results in change(s) of specification limits or modification(s) in potency

sensitivity specificity or purity

bull establishes a new analytical method

bull deletes a specification or an analytical method

bull eliminates tests from the stability protocol or

bull alters the acceptance criteria of the stability protocol

- (20B) Any change in production processes that may

bull result in change(s) of specification limits or modification(s) in potency

sensitivity specificity or purity

bull establish a new analytical method

bull delete a specification or an analytical method

bull eliminate tests from the stability protocol or

bull alter the acceptance criteria of the stability protocol

26

Analytical Validation and Method Detail

(several)

Question Asked a series of questions on method details

requested method validation data for all methods used in

the analytical control strategy

Answer

- Provided copies of the methods and answered the specific

detail questions requested

- Some requests have included providing raw data (eg real

weight of reference standard and sample used) from validation

- This detail is requested as a substitute for in-country testing

thus preventing the need for in-country (repeat) testing

- The procedures are not considered ldquopart of the licenserdquo

Result Success

Method detail (South Korea)

Question Detailed test methods for API

Answer

- Provided descriptions of the assays but not copies of the methods

- These are not considered ldquopart of the licenserdquo (eg The detailed test

methods for Drug Substance are supplied as a reference The

information provided in Module 3 Section 32S42 Analytical

Procedures is considered to contain the regulatory information and

requirements)

Result Success

Detailed data (several)

Question Provide chromatograms and electropherograms for all

stability timepoints

Answer

- Provided chromatogramselectropherograms sometimes providing only

one lot instead of three lots

Result Success

Conclusions

Understanding analytical methods including real time

assessments of variability are becoming increasingly

important

The trends toward increased globalization will create

additional work and challenge for analytical professionals

Global Emerging Markets will become a larger portion of

the work due to increasing complexity in these markets

Acknowledgements

Catherine Anderson

Helena Madden

Sue Stella

Guidance list (non-inclusive) Region Topic ASEAN ASEAN GUIDELINE ON SUBMISSION OF MANUFACTURING PROCESS VALIDATION DATA FOR DRUG REGISTRATION

httpwwwhsagovsgpublishetcmedialibhsa_libraryhealth_products_regulationwestern_medicinesfiles_guidelinesPar96657FiledatA

SEAN20PV20(Version2031)20Main20Guide20without20annexespdf ASEAN VARIATION GUIDELINE FOR PHARMACEUTICAL PRODUCTS

httpwwwfdagovphattachmentsarticle95567ASEAN20Variation20Guideline20for20Pharmaceutical20Products20Final20

Draft207220(2013)pdf Thailand QampA on ASEAN Analytical Validation

httpwwwhsagovsgpublishetcmedialibhsa_libraryhealth_products_regulationwestern_medicinesfiles_guidelinesPar98887FiledatQ

ampA20analytical20validation-25jun55pdf ASEAN website with links to several guidances

httpwwwaseanorgcommunitiesasean-economic-communityitemharmonization-of-standards-and-technical-requirements-in-asean Brazil Resolution RDC No 27

httpwwwemergogroupcomfilesbrazil-resolution-rdc-no-27-21-june-2011pdf

Establishes Minimum Requirements for the Validation of Bioanalytical Methods Used in Pre- and Post-Marketing Studies

The validation of the analytical methods (Resolution RE 899 (IDRAC 39212) of 29-May-20033 and Resolution RDC 27 (IDRAC 143541) of

17-May-2012) is mandatory whenever the method is an in-house method or it is not described in pharmacopeias accepted by ANVISA Resolution RDC No 17

httpwwwabiquifiorgbrlegislacaoanvisaingles_rdc17pdf

16-Apr-2010 presents detailed guidelines about the validation and qualification requirements in the pharmaceutical industry as part of the

Good Manufacturing Practices Regulation Australia Note for Guidance on Validation of Analytical Procedures Text and Methodology

CPMPICH38195 (pdf183kb)

Japan Excerpt from presentation Japan has no guidance for bioanalytical method validation The answers in these slides are the results of the

discussion in the JBF kickoff meeting on March 30 (2011)1048579

httpwwwnihsgojpdrugBMVMontreal20110414_katoripdf Malaysia httpportalbpfkgovmyaeimagesFileAnalytical_Validation_Documents_of_Injections_Submission_Guidelinespdf Singapore ANALYTICAL METHOD VALIDATION

httpwwwhsagovsgpublishetcmedialibhsa_libraryhealth_products_regulationgmpfiles_1Par23186FiledatGUIDE-MQA-012A-

004pdf

Page 2: Capillary Electrophoresis in Global Emerging Markets: …c.ymcdn.com/sites/casss.site-ym.com/resource/resmgr/CE_Pharm...manufacturing process, ... From ASEAN Guideline on Analytical

Agenda

The Lifecycle Approach ndash a guidance review

What it really meanshellip

Global Emerging Markets and their impact on the CE

professional

Selected questions and their answers

Lifecycle management guidance

Health Canada published one in 2004 (GUI-0029)

It was revised in 2009

The activities relating to validation studies may be

classified into three phases

- Phase 1 Pre-Validation Phase or the Qualification Phase

- Phase 2 Process Validation Phase (Process Qualification

phase)

- Phase 3 Validation Maintenance Phase

Other recent guidances have been published by FDA

and EMA (draft)

The guidance is specific to Process Validation however it can be

applied to analytical as well

Process Validation Guidance from FDA (2011)

The guidance aligns process validation activities with the

product lifecycle concept and with existing FDA

guidance

The lifecycle concept links product and process

development qualification of the commercial

manufacturing process and maintenance of the process

in a state of control during routine commercial

production

The concept aligns with expectations for the analytical

validation and ongoing laboratory data generation

FDA Guidance Process validation stages

Stage 1 ndash Process Design development and scale-up

activities

Stage 2 ndash Process Qualification Proof of reproducible

commercial manufacturing

Stage 3 ndash Continued Process Verification Ongoing

assurance of process control

FDA Guidance Process validation stages ndash

applied to the analytical laboratory

Stage 1 ndash Analytical Method Design development and

initial qualification activities

Stage 2 ndash Analytical Method Qualification Proof of

reproducible commercial testing

Stage 3 ndash Continued Analytical Method Verification

Ongoing assurance of analytical control

Expectations of the CE professional

Understand the sources of variation

Detect the presence and degree of variation

Understand the impact of variation on the process and

ultimately on product attributes

Control the variation in a manner commensurate with the

risk it represents to the process and product

Understanding variability

Variability comes in three

forms process sample

and analytical

A control chart of the lot

release values will

encompass all three forms

of variability

It is rare that all three types

can be accurately

quantitated without a

carefully planned and

executed hierarchical or

similar study

σsup2 = σsup2P + σsup2S + σsup2T

Where

σsup2 = Total variance

σsup2P = Process variance

σsup2S = Sampling variance

σsup2T = Test variance

Illustrating Stability

0

2

4

6

8

10

12

14

0 5 10 15 20 25 30 35 40 45 50

If the points fall at random about the centreline

and remain within the control limits the

process is deemed to be stable

Illustrating Instability

0

2

4

6

8

10

12

14

16

18

20

0 5 10 15 20 25 30 35 40 45 50

If this red line is the test specification

should we react to the ldquospecial causerdquo

A better way

0

2

4

6

8

10

12

14

16

18

20

0 5 10 15 20 25 30 35 40 45 500

2

4

6

8

10

12

14

16

18

20

0 5 10 15 20 25 30 35 40 45 50

Re-drawing the limits makes it easy to see

17

18

19

20

21

22

23

24

25

26

27

1 4 7 10 13 16 19 22 25 28 31 34 37 40 43

15

17

19

21

23

25

27

29

31

33

35

1 4 7 10

13

16

19

22

25

28

31

34

37

40

43

Production Data Laboratory Controls

Where Lies The Problem Limits are set as per the usual practice plusmn 3 sigma

Understanding the data

18

19

20

21

22

23

24

25

26

0 5 10 15 20 25 30 35 40 45 50

1-P

oint

Ave

rage

0

05

1

15

2

25

3

35

4

45

5

Ran

ge

20

22

24

26

28

30

32

34

0 5 10 15 20 25 30 35 40 45 50

1-P

oint

Ave

rage

0

2

4

6

8

10

12

Ran

ge

Understanding the data

Shewhart Control Charts are Usedhellip

Global Emerging Markets

For most life cycle management activites focus on the

ldquoreferencerdquo markets eg US EMA Canada Japan

There are of course hundreds of other markets

The prominent and fast growing are referred to as Global

Emerging Markets

These markets are becoming strategically important for

the pharmaceutical industry

Global Emerging Markets

Country IMFNext-

11BRICCIVETS FTSE MSCI

THE

ECONOMI

ST

SampPDOW

JONESBBVA

Columbia

University

EMGP

Argentina

Bahrain

Bangladesh

Brazil

Chile

China

Colombia

Egypt

Hong Kong

India

Indonesia

Israel

Jordan

Kuwait

Malaysia

Mauritius

Mexico

Morocco

Nigeria

Global Emerging Markets

Country IMFNext-

11BRICCIVETS FTSE MSCI

THE

ECONOMI

ST

SampPDOW

JONESBBVA

Columbia

University

EMGP

Oman

Pakistan

Peru

Philippines

Qatar

Russia

Saudi Arabia

Singapore

South Africa

South Korea

Sri Lanka

Taiwan

Thailand

Tunisia

Turkey

UAE

Ukraine

Venezuela

Vietnam

Characteristics of GEM Regulatory Agencies

Many markets expect a major market (eg US or EMA)

approval before filing

- This facilitates approval in these countries

- Notable exceptions South Africa Brazil

Requirements and expertise can vary widely but both

are increasing

- Example Azerbaijan vs Russia vs India

- Example HSA (Singapore)

GEM Challenges

Regulations are evolving

- Advances ICH Pharmaceutical Inspection Coop Scheme

Regulations and guidelines (along with unstated

expectations) are not globally harmonized - Many country or region-specific requirements and interpretation of

guidance

- Pharmacopeia standards differ country to country

- GMPs are not globally harmonized

- Inspections are not globally harmonized

- Differences exist for reviewapproval times clinical trial application

content specification

- Approval of changes is not harmonized

- Post approval reporting requirements are not harmonized

18

GEM Challenges

Increasing complexity with foreign countries

bull Language time zones culture FMAs in-country testing

availability of instrumentation technical savvy

New requirements for some GEM countries

IP issues

Inspections

Multiple approved dossier versions for a single drug

- Multiple specifications multiple item codes different CoAs

different responses to questions

Overall Global CTD not possible

Understanding both the intent and expectations of

questions

19

In-country testing

Many countries require in country testing either before

approval or after launch of the product

Capillary electrophoresis (among other methodologies)

can be a challenge for some markets

Methods need to be robust () to facilitate transfer to

these markets

In-country testing (example)

Country Mandatory Requirement

Small Molecules Biologicals

Full vs Partial testing Local vs Contract Lab

Argentina Yes Yes Full Local Lab mandated

Brazil Yes NA Full Local Lab mandated

Chile Yes Yes Partial is possible Can be contracted out

Uruguay Yes Yes Theoretically full testing selected possible Can be contracted out

Mexico Yes Yes Full Testing (for n=20 batches) Then request a

reduction If tests are too expensive or require

sophisticated equipment reduction is possible

Testing is exempted for orphan drugs

Can be contracted out

Russia Yes Yes Full testing for new registrations Laboratory assigned by

MoH

Turkey Yes Yes Tests performed are based on the product but

normally these include Biological Dissolution

Physical physicochemical controls Content

uniformity amount Microbiological purity and ID

Official analysis institution

of TMOH

Ukraine Yes Yes Full testing State local laboratory

assigned by the MoH

Israel Yes Yes Full testing for the first imported batch and then

upon MoH request

Testing carried out by

MOH Lab

Other countries requiring testing Costa Rica DR El Salvador Ecuador Guatemala Honduras

Nicaragua Panama South Korea etc

GEM Requirements (examples) Brazil (Resolution RDC No 17 16 Apr 2010)

Article 19 Qualification and validation should not be considered only

exercises After the adoption of the qualification andor validation

report it there should have a continuous monitoring program which

must be based on periodic review [Note software validation and re-

validation is called out as a specific self-inspection item]

Article 209 Sole Paragraph Compendial analytical methods do not

require validation but before its implementation there must be

documented evidence of their suitability in the laboratory operating

conditions

Article 312 sect 3 The pharmacopoeial methods should be used for the

validation and performance of the sterility test

Article 463 sect 2 The retrospective validation is no longer encouraged

and is not applicable to the manufacture of sterile products

Article 479 sect 2 A risk assessment should be used to determine the

scope and extent of validation 22

GEM Requirements (examples) Thailand (QampA on ASEAN Analytical Validation)

6 Identify the conditionsscenarios when each of the following is

required to be conducted Full validation Revalidation Verification

Refer to 1 for Full validation and Verification According to ASEAN

Guideline revalidation may be required in the following circumstances

- Change in the synthesis of the drug substance

- Change in the composition of the finished product

- Change in the analytical procedure

From ASEAN Guideline on Analytical Validation (consistent with ICH)

The compendial methods are not required to be validated but merely

verify their suitability under actual conditions of use

23

GEM Requirements (examples) ASEAN Variation Guideline for Pharmaceutical

Products

Major Variation

- No analytical examples (not counting specification changes)

Minor Variation - Prior Approval (MiV-PA)

- Change of test procedure to non-compendial drug substance (must at

least show equivalence to former procedure) ndash MiV-PA9

- Change of in-process controls applied during the manufacture of the drug

substance (including tightening and addition of new in-process test) ndash MiV-

PA6

- Change of in-process controls applied during the manufacture of the drug

product (including tightening and addition of new in-process test) ndash MiV-

PA19

bull Interesting note Any new test method does not concern a novel non-standard

technique or a standard technique used in a novel way

Minor Variation - Notification (MiV-N)

- No analytical examples

24

GEM Requirements (examples) South Africa (Amendments)

Four categories

- Type A - amendments that may be implemented without intervention of or prior

notification to Council

- Type B - amendments that require prior notification

- Type C - amendments that require prior approval

- Type D - amendments that should be considered new applications

Type A Biological examples

- (25) Addition of release tests and or of specifications or tightening of

specifications for intermediates of the APIs

Type B Biological examples

- No analytical examples

25

GEM Requirements (examples) South Africa (Amendments)

Type C Biological examples

- (19B) Any change in analytical methods that

bull results in change(s) of specification limits or modification(s) in potency

sensitivity specificity or purity

bull establishes a new analytical method

bull deletes a specification or an analytical method

bull eliminates tests from the stability protocol or

bull alters the acceptance criteria of the stability protocol

- (20B) Any change in production processes that may

bull result in change(s) of specification limits or modification(s) in potency

sensitivity specificity or purity

bull establish a new analytical method

bull delete a specification or an analytical method

bull eliminate tests from the stability protocol or

bull alter the acceptance criteria of the stability protocol

26

Analytical Validation and Method Detail

(several)

Question Asked a series of questions on method details

requested method validation data for all methods used in

the analytical control strategy

Answer

- Provided copies of the methods and answered the specific

detail questions requested

- Some requests have included providing raw data (eg real

weight of reference standard and sample used) from validation

- This detail is requested as a substitute for in-country testing

thus preventing the need for in-country (repeat) testing

- The procedures are not considered ldquopart of the licenserdquo

Result Success

Method detail (South Korea)

Question Detailed test methods for API

Answer

- Provided descriptions of the assays but not copies of the methods

- These are not considered ldquopart of the licenserdquo (eg The detailed test

methods for Drug Substance are supplied as a reference The

information provided in Module 3 Section 32S42 Analytical

Procedures is considered to contain the regulatory information and

requirements)

Result Success

Detailed data (several)

Question Provide chromatograms and electropherograms for all

stability timepoints

Answer

- Provided chromatogramselectropherograms sometimes providing only

one lot instead of three lots

Result Success

Conclusions

Understanding analytical methods including real time

assessments of variability are becoming increasingly

important

The trends toward increased globalization will create

additional work and challenge for analytical professionals

Global Emerging Markets will become a larger portion of

the work due to increasing complexity in these markets

Acknowledgements

Catherine Anderson

Helena Madden

Sue Stella

Guidance list (non-inclusive) Region Topic ASEAN ASEAN GUIDELINE ON SUBMISSION OF MANUFACTURING PROCESS VALIDATION DATA FOR DRUG REGISTRATION

httpwwwhsagovsgpublishetcmedialibhsa_libraryhealth_products_regulationwestern_medicinesfiles_guidelinesPar96657FiledatA

SEAN20PV20(Version2031)20Main20Guide20without20annexespdf ASEAN VARIATION GUIDELINE FOR PHARMACEUTICAL PRODUCTS

httpwwwfdagovphattachmentsarticle95567ASEAN20Variation20Guideline20for20Pharmaceutical20Products20Final20

Draft207220(2013)pdf Thailand QampA on ASEAN Analytical Validation

httpwwwhsagovsgpublishetcmedialibhsa_libraryhealth_products_regulationwestern_medicinesfiles_guidelinesPar98887FiledatQ

ampA20analytical20validation-25jun55pdf ASEAN website with links to several guidances

httpwwwaseanorgcommunitiesasean-economic-communityitemharmonization-of-standards-and-technical-requirements-in-asean Brazil Resolution RDC No 27

httpwwwemergogroupcomfilesbrazil-resolution-rdc-no-27-21-june-2011pdf

Establishes Minimum Requirements for the Validation of Bioanalytical Methods Used in Pre- and Post-Marketing Studies

The validation of the analytical methods (Resolution RE 899 (IDRAC 39212) of 29-May-20033 and Resolution RDC 27 (IDRAC 143541) of

17-May-2012) is mandatory whenever the method is an in-house method or it is not described in pharmacopeias accepted by ANVISA Resolution RDC No 17

httpwwwabiquifiorgbrlegislacaoanvisaingles_rdc17pdf

16-Apr-2010 presents detailed guidelines about the validation and qualification requirements in the pharmaceutical industry as part of the

Good Manufacturing Practices Regulation Australia Note for Guidance on Validation of Analytical Procedures Text and Methodology

CPMPICH38195 (pdf183kb)

Japan Excerpt from presentation Japan has no guidance for bioanalytical method validation The answers in these slides are the results of the

discussion in the JBF kickoff meeting on March 30 (2011)1048579

httpwwwnihsgojpdrugBMVMontreal20110414_katoripdf Malaysia httpportalbpfkgovmyaeimagesFileAnalytical_Validation_Documents_of_Injections_Submission_Guidelinespdf Singapore ANALYTICAL METHOD VALIDATION

httpwwwhsagovsgpublishetcmedialibhsa_libraryhealth_products_regulationgmpfiles_1Par23186FiledatGUIDE-MQA-012A-

004pdf

Page 3: Capillary Electrophoresis in Global Emerging Markets: …c.ymcdn.com/sites/casss.site-ym.com/resource/resmgr/CE_Pharm...manufacturing process, ... From ASEAN Guideline on Analytical

Lifecycle management guidance

Health Canada published one in 2004 (GUI-0029)

It was revised in 2009

The activities relating to validation studies may be

classified into three phases

- Phase 1 Pre-Validation Phase or the Qualification Phase

- Phase 2 Process Validation Phase (Process Qualification

phase)

- Phase 3 Validation Maintenance Phase

Other recent guidances have been published by FDA

and EMA (draft)

The guidance is specific to Process Validation however it can be

applied to analytical as well

Process Validation Guidance from FDA (2011)

The guidance aligns process validation activities with the

product lifecycle concept and with existing FDA

guidance

The lifecycle concept links product and process

development qualification of the commercial

manufacturing process and maintenance of the process

in a state of control during routine commercial

production

The concept aligns with expectations for the analytical

validation and ongoing laboratory data generation

FDA Guidance Process validation stages

Stage 1 ndash Process Design development and scale-up

activities

Stage 2 ndash Process Qualification Proof of reproducible

commercial manufacturing

Stage 3 ndash Continued Process Verification Ongoing

assurance of process control

FDA Guidance Process validation stages ndash

applied to the analytical laboratory

Stage 1 ndash Analytical Method Design development and

initial qualification activities

Stage 2 ndash Analytical Method Qualification Proof of

reproducible commercial testing

Stage 3 ndash Continued Analytical Method Verification

Ongoing assurance of analytical control

Expectations of the CE professional

Understand the sources of variation

Detect the presence and degree of variation

Understand the impact of variation on the process and

ultimately on product attributes

Control the variation in a manner commensurate with the

risk it represents to the process and product

Understanding variability

Variability comes in three

forms process sample

and analytical

A control chart of the lot

release values will

encompass all three forms

of variability

It is rare that all three types

can be accurately

quantitated without a

carefully planned and

executed hierarchical or

similar study

σsup2 = σsup2P + σsup2S + σsup2T

Where

σsup2 = Total variance

σsup2P = Process variance

σsup2S = Sampling variance

σsup2T = Test variance

Illustrating Stability

0

2

4

6

8

10

12

14

0 5 10 15 20 25 30 35 40 45 50

If the points fall at random about the centreline

and remain within the control limits the

process is deemed to be stable

Illustrating Instability

0

2

4

6

8

10

12

14

16

18

20

0 5 10 15 20 25 30 35 40 45 50

If this red line is the test specification

should we react to the ldquospecial causerdquo

A better way

0

2

4

6

8

10

12

14

16

18

20

0 5 10 15 20 25 30 35 40 45 500

2

4

6

8

10

12

14

16

18

20

0 5 10 15 20 25 30 35 40 45 50

Re-drawing the limits makes it easy to see

17

18

19

20

21

22

23

24

25

26

27

1 4 7 10 13 16 19 22 25 28 31 34 37 40 43

15

17

19

21

23

25

27

29

31

33

35

1 4 7 10

13

16

19

22

25

28

31

34

37

40

43

Production Data Laboratory Controls

Where Lies The Problem Limits are set as per the usual practice plusmn 3 sigma

Understanding the data

18

19

20

21

22

23

24

25

26

0 5 10 15 20 25 30 35 40 45 50

1-P

oint

Ave

rage

0

05

1

15

2

25

3

35

4

45

5

Ran

ge

20

22

24

26

28

30

32

34

0 5 10 15 20 25 30 35 40 45 50

1-P

oint

Ave

rage

0

2

4

6

8

10

12

Ran

ge

Understanding the data

Shewhart Control Charts are Usedhellip

Global Emerging Markets

For most life cycle management activites focus on the

ldquoreferencerdquo markets eg US EMA Canada Japan

There are of course hundreds of other markets

The prominent and fast growing are referred to as Global

Emerging Markets

These markets are becoming strategically important for

the pharmaceutical industry

Global Emerging Markets

Country IMFNext-

11BRICCIVETS FTSE MSCI

THE

ECONOMI

ST

SampPDOW

JONESBBVA

Columbia

University

EMGP

Argentina

Bahrain

Bangladesh

Brazil

Chile

China

Colombia

Egypt

Hong Kong

India

Indonesia

Israel

Jordan

Kuwait

Malaysia

Mauritius

Mexico

Morocco

Nigeria

Global Emerging Markets

Country IMFNext-

11BRICCIVETS FTSE MSCI

THE

ECONOMI

ST

SampPDOW

JONESBBVA

Columbia

University

EMGP

Oman

Pakistan

Peru

Philippines

Qatar

Russia

Saudi Arabia

Singapore

South Africa

South Korea

Sri Lanka

Taiwan

Thailand

Tunisia

Turkey

UAE

Ukraine

Venezuela

Vietnam

Characteristics of GEM Regulatory Agencies

Many markets expect a major market (eg US or EMA)

approval before filing

- This facilitates approval in these countries

- Notable exceptions South Africa Brazil

Requirements and expertise can vary widely but both

are increasing

- Example Azerbaijan vs Russia vs India

- Example HSA (Singapore)

GEM Challenges

Regulations are evolving

- Advances ICH Pharmaceutical Inspection Coop Scheme

Regulations and guidelines (along with unstated

expectations) are not globally harmonized - Many country or region-specific requirements and interpretation of

guidance

- Pharmacopeia standards differ country to country

- GMPs are not globally harmonized

- Inspections are not globally harmonized

- Differences exist for reviewapproval times clinical trial application

content specification

- Approval of changes is not harmonized

- Post approval reporting requirements are not harmonized

18

GEM Challenges

Increasing complexity with foreign countries

bull Language time zones culture FMAs in-country testing

availability of instrumentation technical savvy

New requirements for some GEM countries

IP issues

Inspections

Multiple approved dossier versions for a single drug

- Multiple specifications multiple item codes different CoAs

different responses to questions

Overall Global CTD not possible

Understanding both the intent and expectations of

questions

19

In-country testing

Many countries require in country testing either before

approval or after launch of the product

Capillary electrophoresis (among other methodologies)

can be a challenge for some markets

Methods need to be robust () to facilitate transfer to

these markets

In-country testing (example)

Country Mandatory Requirement

Small Molecules Biologicals

Full vs Partial testing Local vs Contract Lab

Argentina Yes Yes Full Local Lab mandated

Brazil Yes NA Full Local Lab mandated

Chile Yes Yes Partial is possible Can be contracted out

Uruguay Yes Yes Theoretically full testing selected possible Can be contracted out

Mexico Yes Yes Full Testing (for n=20 batches) Then request a

reduction If tests are too expensive or require

sophisticated equipment reduction is possible

Testing is exempted for orphan drugs

Can be contracted out

Russia Yes Yes Full testing for new registrations Laboratory assigned by

MoH

Turkey Yes Yes Tests performed are based on the product but

normally these include Biological Dissolution

Physical physicochemical controls Content

uniformity amount Microbiological purity and ID

Official analysis institution

of TMOH

Ukraine Yes Yes Full testing State local laboratory

assigned by the MoH

Israel Yes Yes Full testing for the first imported batch and then

upon MoH request

Testing carried out by

MOH Lab

Other countries requiring testing Costa Rica DR El Salvador Ecuador Guatemala Honduras

Nicaragua Panama South Korea etc

GEM Requirements (examples) Brazil (Resolution RDC No 17 16 Apr 2010)

Article 19 Qualification and validation should not be considered only

exercises After the adoption of the qualification andor validation

report it there should have a continuous monitoring program which

must be based on periodic review [Note software validation and re-

validation is called out as a specific self-inspection item]

Article 209 Sole Paragraph Compendial analytical methods do not

require validation but before its implementation there must be

documented evidence of their suitability in the laboratory operating

conditions

Article 312 sect 3 The pharmacopoeial methods should be used for the

validation and performance of the sterility test

Article 463 sect 2 The retrospective validation is no longer encouraged

and is not applicable to the manufacture of sterile products

Article 479 sect 2 A risk assessment should be used to determine the

scope and extent of validation 22

GEM Requirements (examples) Thailand (QampA on ASEAN Analytical Validation)

6 Identify the conditionsscenarios when each of the following is

required to be conducted Full validation Revalidation Verification

Refer to 1 for Full validation and Verification According to ASEAN

Guideline revalidation may be required in the following circumstances

- Change in the synthesis of the drug substance

- Change in the composition of the finished product

- Change in the analytical procedure

From ASEAN Guideline on Analytical Validation (consistent with ICH)

The compendial methods are not required to be validated but merely

verify their suitability under actual conditions of use

23

GEM Requirements (examples) ASEAN Variation Guideline for Pharmaceutical

Products

Major Variation

- No analytical examples (not counting specification changes)

Minor Variation - Prior Approval (MiV-PA)

- Change of test procedure to non-compendial drug substance (must at

least show equivalence to former procedure) ndash MiV-PA9

- Change of in-process controls applied during the manufacture of the drug

substance (including tightening and addition of new in-process test) ndash MiV-

PA6

- Change of in-process controls applied during the manufacture of the drug

product (including tightening and addition of new in-process test) ndash MiV-

PA19

bull Interesting note Any new test method does not concern a novel non-standard

technique or a standard technique used in a novel way

Minor Variation - Notification (MiV-N)

- No analytical examples

24

GEM Requirements (examples) South Africa (Amendments)

Four categories

- Type A - amendments that may be implemented without intervention of or prior

notification to Council

- Type B - amendments that require prior notification

- Type C - amendments that require prior approval

- Type D - amendments that should be considered new applications

Type A Biological examples

- (25) Addition of release tests and or of specifications or tightening of

specifications for intermediates of the APIs

Type B Biological examples

- No analytical examples

25

GEM Requirements (examples) South Africa (Amendments)

Type C Biological examples

- (19B) Any change in analytical methods that

bull results in change(s) of specification limits or modification(s) in potency

sensitivity specificity or purity

bull establishes a new analytical method

bull deletes a specification or an analytical method

bull eliminates tests from the stability protocol or

bull alters the acceptance criteria of the stability protocol

- (20B) Any change in production processes that may

bull result in change(s) of specification limits or modification(s) in potency

sensitivity specificity or purity

bull establish a new analytical method

bull delete a specification or an analytical method

bull eliminate tests from the stability protocol or

bull alter the acceptance criteria of the stability protocol

26

Analytical Validation and Method Detail

(several)

Question Asked a series of questions on method details

requested method validation data for all methods used in

the analytical control strategy

Answer

- Provided copies of the methods and answered the specific

detail questions requested

- Some requests have included providing raw data (eg real

weight of reference standard and sample used) from validation

- This detail is requested as a substitute for in-country testing

thus preventing the need for in-country (repeat) testing

- The procedures are not considered ldquopart of the licenserdquo

Result Success

Method detail (South Korea)

Question Detailed test methods for API

Answer

- Provided descriptions of the assays but not copies of the methods

- These are not considered ldquopart of the licenserdquo (eg The detailed test

methods for Drug Substance are supplied as a reference The

information provided in Module 3 Section 32S42 Analytical

Procedures is considered to contain the regulatory information and

requirements)

Result Success

Detailed data (several)

Question Provide chromatograms and electropherograms for all

stability timepoints

Answer

- Provided chromatogramselectropherograms sometimes providing only

one lot instead of three lots

Result Success

Conclusions

Understanding analytical methods including real time

assessments of variability are becoming increasingly

important

The trends toward increased globalization will create

additional work and challenge for analytical professionals

Global Emerging Markets will become a larger portion of

the work due to increasing complexity in these markets

Acknowledgements

Catherine Anderson

Helena Madden

Sue Stella

Guidance list (non-inclusive) Region Topic ASEAN ASEAN GUIDELINE ON SUBMISSION OF MANUFACTURING PROCESS VALIDATION DATA FOR DRUG REGISTRATION

httpwwwhsagovsgpublishetcmedialibhsa_libraryhealth_products_regulationwestern_medicinesfiles_guidelinesPar96657FiledatA

SEAN20PV20(Version2031)20Main20Guide20without20annexespdf ASEAN VARIATION GUIDELINE FOR PHARMACEUTICAL PRODUCTS

httpwwwfdagovphattachmentsarticle95567ASEAN20Variation20Guideline20for20Pharmaceutical20Products20Final20

Draft207220(2013)pdf Thailand QampA on ASEAN Analytical Validation

httpwwwhsagovsgpublishetcmedialibhsa_libraryhealth_products_regulationwestern_medicinesfiles_guidelinesPar98887FiledatQ

ampA20analytical20validation-25jun55pdf ASEAN website with links to several guidances

httpwwwaseanorgcommunitiesasean-economic-communityitemharmonization-of-standards-and-technical-requirements-in-asean Brazil Resolution RDC No 27

httpwwwemergogroupcomfilesbrazil-resolution-rdc-no-27-21-june-2011pdf

Establishes Minimum Requirements for the Validation of Bioanalytical Methods Used in Pre- and Post-Marketing Studies

The validation of the analytical methods (Resolution RE 899 (IDRAC 39212) of 29-May-20033 and Resolution RDC 27 (IDRAC 143541) of

17-May-2012) is mandatory whenever the method is an in-house method or it is not described in pharmacopeias accepted by ANVISA Resolution RDC No 17

httpwwwabiquifiorgbrlegislacaoanvisaingles_rdc17pdf

16-Apr-2010 presents detailed guidelines about the validation and qualification requirements in the pharmaceutical industry as part of the

Good Manufacturing Practices Regulation Australia Note for Guidance on Validation of Analytical Procedures Text and Methodology

CPMPICH38195 (pdf183kb)

Japan Excerpt from presentation Japan has no guidance for bioanalytical method validation The answers in these slides are the results of the

discussion in the JBF kickoff meeting on March 30 (2011)1048579

httpwwwnihsgojpdrugBMVMontreal20110414_katoripdf Malaysia httpportalbpfkgovmyaeimagesFileAnalytical_Validation_Documents_of_Injections_Submission_Guidelinespdf Singapore ANALYTICAL METHOD VALIDATION

httpwwwhsagovsgpublishetcmedialibhsa_libraryhealth_products_regulationgmpfiles_1Par23186FiledatGUIDE-MQA-012A-

004pdf

Page 4: Capillary Electrophoresis in Global Emerging Markets: …c.ymcdn.com/sites/casss.site-ym.com/resource/resmgr/CE_Pharm...manufacturing process, ... From ASEAN Guideline on Analytical

Process Validation Guidance from FDA (2011)

The guidance aligns process validation activities with the

product lifecycle concept and with existing FDA

guidance

The lifecycle concept links product and process

development qualification of the commercial

manufacturing process and maintenance of the process

in a state of control during routine commercial

production

The concept aligns with expectations for the analytical

validation and ongoing laboratory data generation

FDA Guidance Process validation stages

Stage 1 ndash Process Design development and scale-up

activities

Stage 2 ndash Process Qualification Proof of reproducible

commercial manufacturing

Stage 3 ndash Continued Process Verification Ongoing

assurance of process control

FDA Guidance Process validation stages ndash

applied to the analytical laboratory

Stage 1 ndash Analytical Method Design development and

initial qualification activities

Stage 2 ndash Analytical Method Qualification Proof of

reproducible commercial testing

Stage 3 ndash Continued Analytical Method Verification

Ongoing assurance of analytical control

Expectations of the CE professional

Understand the sources of variation

Detect the presence and degree of variation

Understand the impact of variation on the process and

ultimately on product attributes

Control the variation in a manner commensurate with the

risk it represents to the process and product

Understanding variability

Variability comes in three

forms process sample

and analytical

A control chart of the lot

release values will

encompass all three forms

of variability

It is rare that all three types

can be accurately

quantitated without a

carefully planned and

executed hierarchical or

similar study

σsup2 = σsup2P + σsup2S + σsup2T

Where

σsup2 = Total variance

σsup2P = Process variance

σsup2S = Sampling variance

σsup2T = Test variance

Illustrating Stability

0

2

4

6

8

10

12

14

0 5 10 15 20 25 30 35 40 45 50

If the points fall at random about the centreline

and remain within the control limits the

process is deemed to be stable

Illustrating Instability

0

2

4

6

8

10

12

14

16

18

20

0 5 10 15 20 25 30 35 40 45 50

If this red line is the test specification

should we react to the ldquospecial causerdquo

A better way

0

2

4

6

8

10

12

14

16

18

20

0 5 10 15 20 25 30 35 40 45 500

2

4

6

8

10

12

14

16

18

20

0 5 10 15 20 25 30 35 40 45 50

Re-drawing the limits makes it easy to see

17

18

19

20

21

22

23

24

25

26

27

1 4 7 10 13 16 19 22 25 28 31 34 37 40 43

15

17

19

21

23

25

27

29

31

33

35

1 4 7 10

13

16

19

22

25

28

31

34

37

40

43

Production Data Laboratory Controls

Where Lies The Problem Limits are set as per the usual practice plusmn 3 sigma

Understanding the data

18

19

20

21

22

23

24

25

26

0 5 10 15 20 25 30 35 40 45 50

1-P

oint

Ave

rage

0

05

1

15

2

25

3

35

4

45

5

Ran

ge

20

22

24

26

28

30

32

34

0 5 10 15 20 25 30 35 40 45 50

1-P

oint

Ave

rage

0

2

4

6

8

10

12

Ran

ge

Understanding the data

Shewhart Control Charts are Usedhellip

Global Emerging Markets

For most life cycle management activites focus on the

ldquoreferencerdquo markets eg US EMA Canada Japan

There are of course hundreds of other markets

The prominent and fast growing are referred to as Global

Emerging Markets

These markets are becoming strategically important for

the pharmaceutical industry

Global Emerging Markets

Country IMFNext-

11BRICCIVETS FTSE MSCI

THE

ECONOMI

ST

SampPDOW

JONESBBVA

Columbia

University

EMGP

Argentina

Bahrain

Bangladesh

Brazil

Chile

China

Colombia

Egypt

Hong Kong

India

Indonesia

Israel

Jordan

Kuwait

Malaysia

Mauritius

Mexico

Morocco

Nigeria

Global Emerging Markets

Country IMFNext-

11BRICCIVETS FTSE MSCI

THE

ECONOMI

ST

SampPDOW

JONESBBVA

Columbia

University

EMGP

Oman

Pakistan

Peru

Philippines

Qatar

Russia

Saudi Arabia

Singapore

South Africa

South Korea

Sri Lanka

Taiwan

Thailand

Tunisia

Turkey

UAE

Ukraine

Venezuela

Vietnam

Characteristics of GEM Regulatory Agencies

Many markets expect a major market (eg US or EMA)

approval before filing

- This facilitates approval in these countries

- Notable exceptions South Africa Brazil

Requirements and expertise can vary widely but both

are increasing

- Example Azerbaijan vs Russia vs India

- Example HSA (Singapore)

GEM Challenges

Regulations are evolving

- Advances ICH Pharmaceutical Inspection Coop Scheme

Regulations and guidelines (along with unstated

expectations) are not globally harmonized - Many country or region-specific requirements and interpretation of

guidance

- Pharmacopeia standards differ country to country

- GMPs are not globally harmonized

- Inspections are not globally harmonized

- Differences exist for reviewapproval times clinical trial application

content specification

- Approval of changes is not harmonized

- Post approval reporting requirements are not harmonized

18

GEM Challenges

Increasing complexity with foreign countries

bull Language time zones culture FMAs in-country testing

availability of instrumentation technical savvy

New requirements for some GEM countries

IP issues

Inspections

Multiple approved dossier versions for a single drug

- Multiple specifications multiple item codes different CoAs

different responses to questions

Overall Global CTD not possible

Understanding both the intent and expectations of

questions

19

In-country testing

Many countries require in country testing either before

approval or after launch of the product

Capillary electrophoresis (among other methodologies)

can be a challenge for some markets

Methods need to be robust () to facilitate transfer to

these markets

In-country testing (example)

Country Mandatory Requirement

Small Molecules Biologicals

Full vs Partial testing Local vs Contract Lab

Argentina Yes Yes Full Local Lab mandated

Brazil Yes NA Full Local Lab mandated

Chile Yes Yes Partial is possible Can be contracted out

Uruguay Yes Yes Theoretically full testing selected possible Can be contracted out

Mexico Yes Yes Full Testing (for n=20 batches) Then request a

reduction If tests are too expensive or require

sophisticated equipment reduction is possible

Testing is exempted for orphan drugs

Can be contracted out

Russia Yes Yes Full testing for new registrations Laboratory assigned by

MoH

Turkey Yes Yes Tests performed are based on the product but

normally these include Biological Dissolution

Physical physicochemical controls Content

uniformity amount Microbiological purity and ID

Official analysis institution

of TMOH

Ukraine Yes Yes Full testing State local laboratory

assigned by the MoH

Israel Yes Yes Full testing for the first imported batch and then

upon MoH request

Testing carried out by

MOH Lab

Other countries requiring testing Costa Rica DR El Salvador Ecuador Guatemala Honduras

Nicaragua Panama South Korea etc

GEM Requirements (examples) Brazil (Resolution RDC No 17 16 Apr 2010)

Article 19 Qualification and validation should not be considered only

exercises After the adoption of the qualification andor validation

report it there should have a continuous monitoring program which

must be based on periodic review [Note software validation and re-

validation is called out as a specific self-inspection item]

Article 209 Sole Paragraph Compendial analytical methods do not

require validation but before its implementation there must be

documented evidence of their suitability in the laboratory operating

conditions

Article 312 sect 3 The pharmacopoeial methods should be used for the

validation and performance of the sterility test

Article 463 sect 2 The retrospective validation is no longer encouraged

and is not applicable to the manufacture of sterile products

Article 479 sect 2 A risk assessment should be used to determine the

scope and extent of validation 22

GEM Requirements (examples) Thailand (QampA on ASEAN Analytical Validation)

6 Identify the conditionsscenarios when each of the following is

required to be conducted Full validation Revalidation Verification

Refer to 1 for Full validation and Verification According to ASEAN

Guideline revalidation may be required in the following circumstances

- Change in the synthesis of the drug substance

- Change in the composition of the finished product

- Change in the analytical procedure

From ASEAN Guideline on Analytical Validation (consistent with ICH)

The compendial methods are not required to be validated but merely

verify their suitability under actual conditions of use

23

GEM Requirements (examples) ASEAN Variation Guideline for Pharmaceutical

Products

Major Variation

- No analytical examples (not counting specification changes)

Minor Variation - Prior Approval (MiV-PA)

- Change of test procedure to non-compendial drug substance (must at

least show equivalence to former procedure) ndash MiV-PA9

- Change of in-process controls applied during the manufacture of the drug

substance (including tightening and addition of new in-process test) ndash MiV-

PA6

- Change of in-process controls applied during the manufacture of the drug

product (including tightening and addition of new in-process test) ndash MiV-

PA19

bull Interesting note Any new test method does not concern a novel non-standard

technique or a standard technique used in a novel way

Minor Variation - Notification (MiV-N)

- No analytical examples

24

GEM Requirements (examples) South Africa (Amendments)

Four categories

- Type A - amendments that may be implemented without intervention of or prior

notification to Council

- Type B - amendments that require prior notification

- Type C - amendments that require prior approval

- Type D - amendments that should be considered new applications

Type A Biological examples

- (25) Addition of release tests and or of specifications or tightening of

specifications for intermediates of the APIs

Type B Biological examples

- No analytical examples

25

GEM Requirements (examples) South Africa (Amendments)

Type C Biological examples

- (19B) Any change in analytical methods that

bull results in change(s) of specification limits or modification(s) in potency

sensitivity specificity or purity

bull establishes a new analytical method

bull deletes a specification or an analytical method

bull eliminates tests from the stability protocol or

bull alters the acceptance criteria of the stability protocol

- (20B) Any change in production processes that may

bull result in change(s) of specification limits or modification(s) in potency

sensitivity specificity or purity

bull establish a new analytical method

bull delete a specification or an analytical method

bull eliminate tests from the stability protocol or

bull alter the acceptance criteria of the stability protocol

26

Analytical Validation and Method Detail

(several)

Question Asked a series of questions on method details

requested method validation data for all methods used in

the analytical control strategy

Answer

- Provided copies of the methods and answered the specific

detail questions requested

- Some requests have included providing raw data (eg real

weight of reference standard and sample used) from validation

- This detail is requested as a substitute for in-country testing

thus preventing the need for in-country (repeat) testing

- The procedures are not considered ldquopart of the licenserdquo

Result Success

Method detail (South Korea)

Question Detailed test methods for API

Answer

- Provided descriptions of the assays but not copies of the methods

- These are not considered ldquopart of the licenserdquo (eg The detailed test

methods for Drug Substance are supplied as a reference The

information provided in Module 3 Section 32S42 Analytical

Procedures is considered to contain the regulatory information and

requirements)

Result Success

Detailed data (several)

Question Provide chromatograms and electropherograms for all

stability timepoints

Answer

- Provided chromatogramselectropherograms sometimes providing only

one lot instead of three lots

Result Success

Conclusions

Understanding analytical methods including real time

assessments of variability are becoming increasingly

important

The trends toward increased globalization will create

additional work and challenge for analytical professionals

Global Emerging Markets will become a larger portion of

the work due to increasing complexity in these markets

Acknowledgements

Catherine Anderson

Helena Madden

Sue Stella

Guidance list (non-inclusive) Region Topic ASEAN ASEAN GUIDELINE ON SUBMISSION OF MANUFACTURING PROCESS VALIDATION DATA FOR DRUG REGISTRATION

httpwwwhsagovsgpublishetcmedialibhsa_libraryhealth_products_regulationwestern_medicinesfiles_guidelinesPar96657FiledatA

SEAN20PV20(Version2031)20Main20Guide20without20annexespdf ASEAN VARIATION GUIDELINE FOR PHARMACEUTICAL PRODUCTS

httpwwwfdagovphattachmentsarticle95567ASEAN20Variation20Guideline20for20Pharmaceutical20Products20Final20

Draft207220(2013)pdf Thailand QampA on ASEAN Analytical Validation

httpwwwhsagovsgpublishetcmedialibhsa_libraryhealth_products_regulationwestern_medicinesfiles_guidelinesPar98887FiledatQ

ampA20analytical20validation-25jun55pdf ASEAN website with links to several guidances

httpwwwaseanorgcommunitiesasean-economic-communityitemharmonization-of-standards-and-technical-requirements-in-asean Brazil Resolution RDC No 27

httpwwwemergogroupcomfilesbrazil-resolution-rdc-no-27-21-june-2011pdf

Establishes Minimum Requirements for the Validation of Bioanalytical Methods Used in Pre- and Post-Marketing Studies

The validation of the analytical methods (Resolution RE 899 (IDRAC 39212) of 29-May-20033 and Resolution RDC 27 (IDRAC 143541) of

17-May-2012) is mandatory whenever the method is an in-house method or it is not described in pharmacopeias accepted by ANVISA Resolution RDC No 17

httpwwwabiquifiorgbrlegislacaoanvisaingles_rdc17pdf

16-Apr-2010 presents detailed guidelines about the validation and qualification requirements in the pharmaceutical industry as part of the

Good Manufacturing Practices Regulation Australia Note for Guidance on Validation of Analytical Procedures Text and Methodology

CPMPICH38195 (pdf183kb)

Japan Excerpt from presentation Japan has no guidance for bioanalytical method validation The answers in these slides are the results of the

discussion in the JBF kickoff meeting on March 30 (2011)1048579

httpwwwnihsgojpdrugBMVMontreal20110414_katoripdf Malaysia httpportalbpfkgovmyaeimagesFileAnalytical_Validation_Documents_of_Injections_Submission_Guidelinespdf Singapore ANALYTICAL METHOD VALIDATION

httpwwwhsagovsgpublishetcmedialibhsa_libraryhealth_products_regulationgmpfiles_1Par23186FiledatGUIDE-MQA-012A-

004pdf

Page 5: Capillary Electrophoresis in Global Emerging Markets: …c.ymcdn.com/sites/casss.site-ym.com/resource/resmgr/CE_Pharm...manufacturing process, ... From ASEAN Guideline on Analytical

FDA Guidance Process validation stages

Stage 1 ndash Process Design development and scale-up

activities

Stage 2 ndash Process Qualification Proof of reproducible

commercial manufacturing

Stage 3 ndash Continued Process Verification Ongoing

assurance of process control

FDA Guidance Process validation stages ndash

applied to the analytical laboratory

Stage 1 ndash Analytical Method Design development and

initial qualification activities

Stage 2 ndash Analytical Method Qualification Proof of

reproducible commercial testing

Stage 3 ndash Continued Analytical Method Verification

Ongoing assurance of analytical control

Expectations of the CE professional

Understand the sources of variation

Detect the presence and degree of variation

Understand the impact of variation on the process and

ultimately on product attributes

Control the variation in a manner commensurate with the

risk it represents to the process and product

Understanding variability

Variability comes in three

forms process sample

and analytical

A control chart of the lot

release values will

encompass all three forms

of variability

It is rare that all three types

can be accurately

quantitated without a

carefully planned and

executed hierarchical or

similar study

σsup2 = σsup2P + σsup2S + σsup2T

Where

σsup2 = Total variance

σsup2P = Process variance

σsup2S = Sampling variance

σsup2T = Test variance

Illustrating Stability

0

2

4

6

8

10

12

14

0 5 10 15 20 25 30 35 40 45 50

If the points fall at random about the centreline

and remain within the control limits the

process is deemed to be stable

Illustrating Instability

0

2

4

6

8

10

12

14

16

18

20

0 5 10 15 20 25 30 35 40 45 50

If this red line is the test specification

should we react to the ldquospecial causerdquo

A better way

0

2

4

6

8

10

12

14

16

18

20

0 5 10 15 20 25 30 35 40 45 500

2

4

6

8

10

12

14

16

18

20

0 5 10 15 20 25 30 35 40 45 50

Re-drawing the limits makes it easy to see

17

18

19

20

21

22

23

24

25

26

27

1 4 7 10 13 16 19 22 25 28 31 34 37 40 43

15

17

19

21

23

25

27

29

31

33

35

1 4 7 10

13

16

19

22

25

28

31

34

37

40

43

Production Data Laboratory Controls

Where Lies The Problem Limits are set as per the usual practice plusmn 3 sigma

Understanding the data

18

19

20

21

22

23

24

25

26

0 5 10 15 20 25 30 35 40 45 50

1-P

oint

Ave

rage

0

05

1

15

2

25

3

35

4

45

5

Ran

ge

20

22

24

26

28

30

32

34

0 5 10 15 20 25 30 35 40 45 50

1-P

oint

Ave

rage

0

2

4

6

8

10

12

Ran

ge

Understanding the data

Shewhart Control Charts are Usedhellip

Global Emerging Markets

For most life cycle management activites focus on the

ldquoreferencerdquo markets eg US EMA Canada Japan

There are of course hundreds of other markets

The prominent and fast growing are referred to as Global

Emerging Markets

These markets are becoming strategically important for

the pharmaceutical industry

Global Emerging Markets

Country IMFNext-

11BRICCIVETS FTSE MSCI

THE

ECONOMI

ST

SampPDOW

JONESBBVA

Columbia

University

EMGP

Argentina

Bahrain

Bangladesh

Brazil

Chile

China

Colombia

Egypt

Hong Kong

India

Indonesia

Israel

Jordan

Kuwait

Malaysia

Mauritius

Mexico

Morocco

Nigeria

Global Emerging Markets

Country IMFNext-

11BRICCIVETS FTSE MSCI

THE

ECONOMI

ST

SampPDOW

JONESBBVA

Columbia

University

EMGP

Oman

Pakistan

Peru

Philippines

Qatar

Russia

Saudi Arabia

Singapore

South Africa

South Korea

Sri Lanka

Taiwan

Thailand

Tunisia

Turkey

UAE

Ukraine

Venezuela

Vietnam

Characteristics of GEM Regulatory Agencies

Many markets expect a major market (eg US or EMA)

approval before filing

- This facilitates approval in these countries

- Notable exceptions South Africa Brazil

Requirements and expertise can vary widely but both

are increasing

- Example Azerbaijan vs Russia vs India

- Example HSA (Singapore)

GEM Challenges

Regulations are evolving

- Advances ICH Pharmaceutical Inspection Coop Scheme

Regulations and guidelines (along with unstated

expectations) are not globally harmonized - Many country or region-specific requirements and interpretation of

guidance

- Pharmacopeia standards differ country to country

- GMPs are not globally harmonized

- Inspections are not globally harmonized

- Differences exist for reviewapproval times clinical trial application

content specification

- Approval of changes is not harmonized

- Post approval reporting requirements are not harmonized

18

GEM Challenges

Increasing complexity with foreign countries

bull Language time zones culture FMAs in-country testing

availability of instrumentation technical savvy

New requirements for some GEM countries

IP issues

Inspections

Multiple approved dossier versions for a single drug

- Multiple specifications multiple item codes different CoAs

different responses to questions

Overall Global CTD not possible

Understanding both the intent and expectations of

questions

19

In-country testing

Many countries require in country testing either before

approval or after launch of the product

Capillary electrophoresis (among other methodologies)

can be a challenge for some markets

Methods need to be robust () to facilitate transfer to

these markets

In-country testing (example)

Country Mandatory Requirement

Small Molecules Biologicals

Full vs Partial testing Local vs Contract Lab

Argentina Yes Yes Full Local Lab mandated

Brazil Yes NA Full Local Lab mandated

Chile Yes Yes Partial is possible Can be contracted out

Uruguay Yes Yes Theoretically full testing selected possible Can be contracted out

Mexico Yes Yes Full Testing (for n=20 batches) Then request a

reduction If tests are too expensive or require

sophisticated equipment reduction is possible

Testing is exempted for orphan drugs

Can be contracted out

Russia Yes Yes Full testing for new registrations Laboratory assigned by

MoH

Turkey Yes Yes Tests performed are based on the product but

normally these include Biological Dissolution

Physical physicochemical controls Content

uniformity amount Microbiological purity and ID

Official analysis institution

of TMOH

Ukraine Yes Yes Full testing State local laboratory

assigned by the MoH

Israel Yes Yes Full testing for the first imported batch and then

upon MoH request

Testing carried out by

MOH Lab

Other countries requiring testing Costa Rica DR El Salvador Ecuador Guatemala Honduras

Nicaragua Panama South Korea etc

GEM Requirements (examples) Brazil (Resolution RDC No 17 16 Apr 2010)

Article 19 Qualification and validation should not be considered only

exercises After the adoption of the qualification andor validation

report it there should have a continuous monitoring program which

must be based on periodic review [Note software validation and re-

validation is called out as a specific self-inspection item]

Article 209 Sole Paragraph Compendial analytical methods do not

require validation but before its implementation there must be

documented evidence of their suitability in the laboratory operating

conditions

Article 312 sect 3 The pharmacopoeial methods should be used for the

validation and performance of the sterility test

Article 463 sect 2 The retrospective validation is no longer encouraged

and is not applicable to the manufacture of sterile products

Article 479 sect 2 A risk assessment should be used to determine the

scope and extent of validation 22

GEM Requirements (examples) Thailand (QampA on ASEAN Analytical Validation)

6 Identify the conditionsscenarios when each of the following is

required to be conducted Full validation Revalidation Verification

Refer to 1 for Full validation and Verification According to ASEAN

Guideline revalidation may be required in the following circumstances

- Change in the synthesis of the drug substance

- Change in the composition of the finished product

- Change in the analytical procedure

From ASEAN Guideline on Analytical Validation (consistent with ICH)

The compendial methods are not required to be validated but merely

verify their suitability under actual conditions of use

23

GEM Requirements (examples) ASEAN Variation Guideline for Pharmaceutical

Products

Major Variation

- No analytical examples (not counting specification changes)

Minor Variation - Prior Approval (MiV-PA)

- Change of test procedure to non-compendial drug substance (must at

least show equivalence to former procedure) ndash MiV-PA9

- Change of in-process controls applied during the manufacture of the drug

substance (including tightening and addition of new in-process test) ndash MiV-

PA6

- Change of in-process controls applied during the manufacture of the drug

product (including tightening and addition of new in-process test) ndash MiV-

PA19

bull Interesting note Any new test method does not concern a novel non-standard

technique or a standard technique used in a novel way

Minor Variation - Notification (MiV-N)

- No analytical examples

24

GEM Requirements (examples) South Africa (Amendments)

Four categories

- Type A - amendments that may be implemented without intervention of or prior

notification to Council

- Type B - amendments that require prior notification

- Type C - amendments that require prior approval

- Type D - amendments that should be considered new applications

Type A Biological examples

- (25) Addition of release tests and or of specifications or tightening of

specifications for intermediates of the APIs

Type B Biological examples

- No analytical examples

25

GEM Requirements (examples) South Africa (Amendments)

Type C Biological examples

- (19B) Any change in analytical methods that

bull results in change(s) of specification limits or modification(s) in potency

sensitivity specificity or purity

bull establishes a new analytical method

bull deletes a specification or an analytical method

bull eliminates tests from the stability protocol or

bull alters the acceptance criteria of the stability protocol

- (20B) Any change in production processes that may

bull result in change(s) of specification limits or modification(s) in potency

sensitivity specificity or purity

bull establish a new analytical method

bull delete a specification or an analytical method

bull eliminate tests from the stability protocol or

bull alter the acceptance criteria of the stability protocol

26

Analytical Validation and Method Detail

(several)

Question Asked a series of questions on method details

requested method validation data for all methods used in

the analytical control strategy

Answer

- Provided copies of the methods and answered the specific

detail questions requested

- Some requests have included providing raw data (eg real

weight of reference standard and sample used) from validation

- This detail is requested as a substitute for in-country testing

thus preventing the need for in-country (repeat) testing

- The procedures are not considered ldquopart of the licenserdquo

Result Success

Method detail (South Korea)

Question Detailed test methods for API

Answer

- Provided descriptions of the assays but not copies of the methods

- These are not considered ldquopart of the licenserdquo (eg The detailed test

methods for Drug Substance are supplied as a reference The

information provided in Module 3 Section 32S42 Analytical

Procedures is considered to contain the regulatory information and

requirements)

Result Success

Detailed data (several)

Question Provide chromatograms and electropherograms for all

stability timepoints

Answer

- Provided chromatogramselectropherograms sometimes providing only

one lot instead of three lots

Result Success

Conclusions

Understanding analytical methods including real time

assessments of variability are becoming increasingly

important

The trends toward increased globalization will create

additional work and challenge for analytical professionals

Global Emerging Markets will become a larger portion of

the work due to increasing complexity in these markets

Acknowledgements

Catherine Anderson

Helena Madden

Sue Stella

Guidance list (non-inclusive) Region Topic ASEAN ASEAN GUIDELINE ON SUBMISSION OF MANUFACTURING PROCESS VALIDATION DATA FOR DRUG REGISTRATION

httpwwwhsagovsgpublishetcmedialibhsa_libraryhealth_products_regulationwestern_medicinesfiles_guidelinesPar96657FiledatA

SEAN20PV20(Version2031)20Main20Guide20without20annexespdf ASEAN VARIATION GUIDELINE FOR PHARMACEUTICAL PRODUCTS

httpwwwfdagovphattachmentsarticle95567ASEAN20Variation20Guideline20for20Pharmaceutical20Products20Final20

Draft207220(2013)pdf Thailand QampA on ASEAN Analytical Validation

httpwwwhsagovsgpublishetcmedialibhsa_libraryhealth_products_regulationwestern_medicinesfiles_guidelinesPar98887FiledatQ

ampA20analytical20validation-25jun55pdf ASEAN website with links to several guidances

httpwwwaseanorgcommunitiesasean-economic-communityitemharmonization-of-standards-and-technical-requirements-in-asean Brazil Resolution RDC No 27

httpwwwemergogroupcomfilesbrazil-resolution-rdc-no-27-21-june-2011pdf

Establishes Minimum Requirements for the Validation of Bioanalytical Methods Used in Pre- and Post-Marketing Studies

The validation of the analytical methods (Resolution RE 899 (IDRAC 39212) of 29-May-20033 and Resolution RDC 27 (IDRAC 143541) of

17-May-2012) is mandatory whenever the method is an in-house method or it is not described in pharmacopeias accepted by ANVISA Resolution RDC No 17

httpwwwabiquifiorgbrlegislacaoanvisaingles_rdc17pdf

16-Apr-2010 presents detailed guidelines about the validation and qualification requirements in the pharmaceutical industry as part of the

Good Manufacturing Practices Regulation Australia Note for Guidance on Validation of Analytical Procedures Text and Methodology

CPMPICH38195 (pdf183kb)

Japan Excerpt from presentation Japan has no guidance for bioanalytical method validation The answers in these slides are the results of the

discussion in the JBF kickoff meeting on March 30 (2011)1048579

httpwwwnihsgojpdrugBMVMontreal20110414_katoripdf Malaysia httpportalbpfkgovmyaeimagesFileAnalytical_Validation_Documents_of_Injections_Submission_Guidelinespdf Singapore ANALYTICAL METHOD VALIDATION

httpwwwhsagovsgpublishetcmedialibhsa_libraryhealth_products_regulationgmpfiles_1Par23186FiledatGUIDE-MQA-012A-

004pdf

Page 6: Capillary Electrophoresis in Global Emerging Markets: …c.ymcdn.com/sites/casss.site-ym.com/resource/resmgr/CE_Pharm...manufacturing process, ... From ASEAN Guideline on Analytical

FDA Guidance Process validation stages ndash

applied to the analytical laboratory

Stage 1 ndash Analytical Method Design development and

initial qualification activities

Stage 2 ndash Analytical Method Qualification Proof of

reproducible commercial testing

Stage 3 ndash Continued Analytical Method Verification

Ongoing assurance of analytical control

Expectations of the CE professional

Understand the sources of variation

Detect the presence and degree of variation

Understand the impact of variation on the process and

ultimately on product attributes

Control the variation in a manner commensurate with the

risk it represents to the process and product

Understanding variability

Variability comes in three

forms process sample

and analytical

A control chart of the lot

release values will

encompass all three forms

of variability

It is rare that all three types

can be accurately

quantitated without a

carefully planned and

executed hierarchical or

similar study

σsup2 = σsup2P + σsup2S + σsup2T

Where

σsup2 = Total variance

σsup2P = Process variance

σsup2S = Sampling variance

σsup2T = Test variance

Illustrating Stability

0

2

4

6

8

10

12

14

0 5 10 15 20 25 30 35 40 45 50

If the points fall at random about the centreline

and remain within the control limits the

process is deemed to be stable

Illustrating Instability

0

2

4

6

8

10

12

14

16

18

20

0 5 10 15 20 25 30 35 40 45 50

If this red line is the test specification

should we react to the ldquospecial causerdquo

A better way

0

2

4

6

8

10

12

14

16

18

20

0 5 10 15 20 25 30 35 40 45 500

2

4

6

8

10

12

14

16

18

20

0 5 10 15 20 25 30 35 40 45 50

Re-drawing the limits makes it easy to see

17

18

19

20

21

22

23

24

25

26

27

1 4 7 10 13 16 19 22 25 28 31 34 37 40 43

15

17

19

21

23

25

27

29

31

33

35

1 4 7 10

13

16

19

22

25

28

31

34

37

40

43

Production Data Laboratory Controls

Where Lies The Problem Limits are set as per the usual practice plusmn 3 sigma

Understanding the data

18

19

20

21

22

23

24

25

26

0 5 10 15 20 25 30 35 40 45 50

1-P

oint

Ave

rage

0

05

1

15

2

25

3

35

4

45

5

Ran

ge

20

22

24

26

28

30

32

34

0 5 10 15 20 25 30 35 40 45 50

1-P

oint

Ave

rage

0

2

4

6

8

10

12

Ran

ge

Understanding the data

Shewhart Control Charts are Usedhellip

Global Emerging Markets

For most life cycle management activites focus on the

ldquoreferencerdquo markets eg US EMA Canada Japan

There are of course hundreds of other markets

The prominent and fast growing are referred to as Global

Emerging Markets

These markets are becoming strategically important for

the pharmaceutical industry

Global Emerging Markets

Country IMFNext-

11BRICCIVETS FTSE MSCI

THE

ECONOMI

ST

SampPDOW

JONESBBVA

Columbia

University

EMGP

Argentina

Bahrain

Bangladesh

Brazil

Chile

China

Colombia

Egypt

Hong Kong

India

Indonesia

Israel

Jordan

Kuwait

Malaysia

Mauritius

Mexico

Morocco

Nigeria

Global Emerging Markets

Country IMFNext-

11BRICCIVETS FTSE MSCI

THE

ECONOMI

ST

SampPDOW

JONESBBVA

Columbia

University

EMGP

Oman

Pakistan

Peru

Philippines

Qatar

Russia

Saudi Arabia

Singapore

South Africa

South Korea

Sri Lanka

Taiwan

Thailand

Tunisia

Turkey

UAE

Ukraine

Venezuela

Vietnam

Characteristics of GEM Regulatory Agencies

Many markets expect a major market (eg US or EMA)

approval before filing

- This facilitates approval in these countries

- Notable exceptions South Africa Brazil

Requirements and expertise can vary widely but both

are increasing

- Example Azerbaijan vs Russia vs India

- Example HSA (Singapore)

GEM Challenges

Regulations are evolving

- Advances ICH Pharmaceutical Inspection Coop Scheme

Regulations and guidelines (along with unstated

expectations) are not globally harmonized - Many country or region-specific requirements and interpretation of

guidance

- Pharmacopeia standards differ country to country

- GMPs are not globally harmonized

- Inspections are not globally harmonized

- Differences exist for reviewapproval times clinical trial application

content specification

- Approval of changes is not harmonized

- Post approval reporting requirements are not harmonized

18

GEM Challenges

Increasing complexity with foreign countries

bull Language time zones culture FMAs in-country testing

availability of instrumentation technical savvy

New requirements for some GEM countries

IP issues

Inspections

Multiple approved dossier versions for a single drug

- Multiple specifications multiple item codes different CoAs

different responses to questions

Overall Global CTD not possible

Understanding both the intent and expectations of

questions

19

In-country testing

Many countries require in country testing either before

approval or after launch of the product

Capillary electrophoresis (among other methodologies)

can be a challenge for some markets

Methods need to be robust () to facilitate transfer to

these markets

In-country testing (example)

Country Mandatory Requirement

Small Molecules Biologicals

Full vs Partial testing Local vs Contract Lab

Argentina Yes Yes Full Local Lab mandated

Brazil Yes NA Full Local Lab mandated

Chile Yes Yes Partial is possible Can be contracted out

Uruguay Yes Yes Theoretically full testing selected possible Can be contracted out

Mexico Yes Yes Full Testing (for n=20 batches) Then request a

reduction If tests are too expensive or require

sophisticated equipment reduction is possible

Testing is exempted for orphan drugs

Can be contracted out

Russia Yes Yes Full testing for new registrations Laboratory assigned by

MoH

Turkey Yes Yes Tests performed are based on the product but

normally these include Biological Dissolution

Physical physicochemical controls Content

uniformity amount Microbiological purity and ID

Official analysis institution

of TMOH

Ukraine Yes Yes Full testing State local laboratory

assigned by the MoH

Israel Yes Yes Full testing for the first imported batch and then

upon MoH request

Testing carried out by

MOH Lab

Other countries requiring testing Costa Rica DR El Salvador Ecuador Guatemala Honduras

Nicaragua Panama South Korea etc

GEM Requirements (examples) Brazil (Resolution RDC No 17 16 Apr 2010)

Article 19 Qualification and validation should not be considered only

exercises After the adoption of the qualification andor validation

report it there should have a continuous monitoring program which

must be based on periodic review [Note software validation and re-

validation is called out as a specific self-inspection item]

Article 209 Sole Paragraph Compendial analytical methods do not

require validation but before its implementation there must be

documented evidence of their suitability in the laboratory operating

conditions

Article 312 sect 3 The pharmacopoeial methods should be used for the

validation and performance of the sterility test

Article 463 sect 2 The retrospective validation is no longer encouraged

and is not applicable to the manufacture of sterile products

Article 479 sect 2 A risk assessment should be used to determine the

scope and extent of validation 22

GEM Requirements (examples) Thailand (QampA on ASEAN Analytical Validation)

6 Identify the conditionsscenarios when each of the following is

required to be conducted Full validation Revalidation Verification

Refer to 1 for Full validation and Verification According to ASEAN

Guideline revalidation may be required in the following circumstances

- Change in the synthesis of the drug substance

- Change in the composition of the finished product

- Change in the analytical procedure

From ASEAN Guideline on Analytical Validation (consistent with ICH)

The compendial methods are not required to be validated but merely

verify their suitability under actual conditions of use

23

GEM Requirements (examples) ASEAN Variation Guideline for Pharmaceutical

Products

Major Variation

- No analytical examples (not counting specification changes)

Minor Variation - Prior Approval (MiV-PA)

- Change of test procedure to non-compendial drug substance (must at

least show equivalence to former procedure) ndash MiV-PA9

- Change of in-process controls applied during the manufacture of the drug

substance (including tightening and addition of new in-process test) ndash MiV-

PA6

- Change of in-process controls applied during the manufacture of the drug

product (including tightening and addition of new in-process test) ndash MiV-

PA19

bull Interesting note Any new test method does not concern a novel non-standard

technique or a standard technique used in a novel way

Minor Variation - Notification (MiV-N)

- No analytical examples

24

GEM Requirements (examples) South Africa (Amendments)

Four categories

- Type A - amendments that may be implemented without intervention of or prior

notification to Council

- Type B - amendments that require prior notification

- Type C - amendments that require prior approval

- Type D - amendments that should be considered new applications

Type A Biological examples

- (25) Addition of release tests and or of specifications or tightening of

specifications for intermediates of the APIs

Type B Biological examples

- No analytical examples

25

GEM Requirements (examples) South Africa (Amendments)

Type C Biological examples

- (19B) Any change in analytical methods that

bull results in change(s) of specification limits or modification(s) in potency

sensitivity specificity or purity

bull establishes a new analytical method

bull deletes a specification or an analytical method

bull eliminates tests from the stability protocol or

bull alters the acceptance criteria of the stability protocol

- (20B) Any change in production processes that may

bull result in change(s) of specification limits or modification(s) in potency

sensitivity specificity or purity

bull establish a new analytical method

bull delete a specification or an analytical method

bull eliminate tests from the stability protocol or

bull alter the acceptance criteria of the stability protocol

26

Analytical Validation and Method Detail

(several)

Question Asked a series of questions on method details

requested method validation data for all methods used in

the analytical control strategy

Answer

- Provided copies of the methods and answered the specific

detail questions requested

- Some requests have included providing raw data (eg real

weight of reference standard and sample used) from validation

- This detail is requested as a substitute for in-country testing

thus preventing the need for in-country (repeat) testing

- The procedures are not considered ldquopart of the licenserdquo

Result Success

Method detail (South Korea)

Question Detailed test methods for API

Answer

- Provided descriptions of the assays but not copies of the methods

- These are not considered ldquopart of the licenserdquo (eg The detailed test

methods for Drug Substance are supplied as a reference The

information provided in Module 3 Section 32S42 Analytical

Procedures is considered to contain the regulatory information and

requirements)

Result Success

Detailed data (several)

Question Provide chromatograms and electropherograms for all

stability timepoints

Answer

- Provided chromatogramselectropherograms sometimes providing only

one lot instead of three lots

Result Success

Conclusions

Understanding analytical methods including real time

assessments of variability are becoming increasingly

important

The trends toward increased globalization will create

additional work and challenge for analytical professionals

Global Emerging Markets will become a larger portion of

the work due to increasing complexity in these markets

Acknowledgements

Catherine Anderson

Helena Madden

Sue Stella

Guidance list (non-inclusive) Region Topic ASEAN ASEAN GUIDELINE ON SUBMISSION OF MANUFACTURING PROCESS VALIDATION DATA FOR DRUG REGISTRATION

httpwwwhsagovsgpublishetcmedialibhsa_libraryhealth_products_regulationwestern_medicinesfiles_guidelinesPar96657FiledatA

SEAN20PV20(Version2031)20Main20Guide20without20annexespdf ASEAN VARIATION GUIDELINE FOR PHARMACEUTICAL PRODUCTS

httpwwwfdagovphattachmentsarticle95567ASEAN20Variation20Guideline20for20Pharmaceutical20Products20Final20

Draft207220(2013)pdf Thailand QampA on ASEAN Analytical Validation

httpwwwhsagovsgpublishetcmedialibhsa_libraryhealth_products_regulationwestern_medicinesfiles_guidelinesPar98887FiledatQ

ampA20analytical20validation-25jun55pdf ASEAN website with links to several guidances

httpwwwaseanorgcommunitiesasean-economic-communityitemharmonization-of-standards-and-technical-requirements-in-asean Brazil Resolution RDC No 27

httpwwwemergogroupcomfilesbrazil-resolution-rdc-no-27-21-june-2011pdf

Establishes Minimum Requirements for the Validation of Bioanalytical Methods Used in Pre- and Post-Marketing Studies

The validation of the analytical methods (Resolution RE 899 (IDRAC 39212) of 29-May-20033 and Resolution RDC 27 (IDRAC 143541) of

17-May-2012) is mandatory whenever the method is an in-house method or it is not described in pharmacopeias accepted by ANVISA Resolution RDC No 17

httpwwwabiquifiorgbrlegislacaoanvisaingles_rdc17pdf

16-Apr-2010 presents detailed guidelines about the validation and qualification requirements in the pharmaceutical industry as part of the

Good Manufacturing Practices Regulation Australia Note for Guidance on Validation of Analytical Procedures Text and Methodology

CPMPICH38195 (pdf183kb)

Japan Excerpt from presentation Japan has no guidance for bioanalytical method validation The answers in these slides are the results of the

discussion in the JBF kickoff meeting on March 30 (2011)1048579

httpwwwnihsgojpdrugBMVMontreal20110414_katoripdf Malaysia httpportalbpfkgovmyaeimagesFileAnalytical_Validation_Documents_of_Injections_Submission_Guidelinespdf Singapore ANALYTICAL METHOD VALIDATION

httpwwwhsagovsgpublishetcmedialibhsa_libraryhealth_products_regulationgmpfiles_1Par23186FiledatGUIDE-MQA-012A-

004pdf

Page 7: Capillary Electrophoresis in Global Emerging Markets: …c.ymcdn.com/sites/casss.site-ym.com/resource/resmgr/CE_Pharm...manufacturing process, ... From ASEAN Guideline on Analytical

Expectations of the CE professional

Understand the sources of variation

Detect the presence and degree of variation

Understand the impact of variation on the process and

ultimately on product attributes

Control the variation in a manner commensurate with the

risk it represents to the process and product

Understanding variability

Variability comes in three

forms process sample

and analytical

A control chart of the lot

release values will

encompass all three forms

of variability

It is rare that all three types

can be accurately

quantitated without a

carefully planned and

executed hierarchical or

similar study

σsup2 = σsup2P + σsup2S + σsup2T

Where

σsup2 = Total variance

σsup2P = Process variance

σsup2S = Sampling variance

σsup2T = Test variance

Illustrating Stability

0

2

4

6

8

10

12

14

0 5 10 15 20 25 30 35 40 45 50

If the points fall at random about the centreline

and remain within the control limits the

process is deemed to be stable

Illustrating Instability

0

2

4

6

8

10

12

14

16

18

20

0 5 10 15 20 25 30 35 40 45 50

If this red line is the test specification

should we react to the ldquospecial causerdquo

A better way

0

2

4

6

8

10

12

14

16

18

20

0 5 10 15 20 25 30 35 40 45 500

2

4

6

8

10

12

14

16

18

20

0 5 10 15 20 25 30 35 40 45 50

Re-drawing the limits makes it easy to see

17

18

19

20

21

22

23

24

25

26

27

1 4 7 10 13 16 19 22 25 28 31 34 37 40 43

15

17

19

21

23

25

27

29

31

33

35

1 4 7 10

13

16

19

22

25

28

31

34

37

40

43

Production Data Laboratory Controls

Where Lies The Problem Limits are set as per the usual practice plusmn 3 sigma

Understanding the data

18

19

20

21

22

23

24

25

26

0 5 10 15 20 25 30 35 40 45 50

1-P

oint

Ave

rage

0

05

1

15

2

25

3

35

4

45

5

Ran

ge

20

22

24

26

28

30

32

34

0 5 10 15 20 25 30 35 40 45 50

1-P

oint

Ave

rage

0

2

4

6

8

10

12

Ran

ge

Understanding the data

Shewhart Control Charts are Usedhellip

Global Emerging Markets

For most life cycle management activites focus on the

ldquoreferencerdquo markets eg US EMA Canada Japan

There are of course hundreds of other markets

The prominent and fast growing are referred to as Global

Emerging Markets

These markets are becoming strategically important for

the pharmaceutical industry

Global Emerging Markets

Country IMFNext-

11BRICCIVETS FTSE MSCI

THE

ECONOMI

ST

SampPDOW

JONESBBVA

Columbia

University

EMGP

Argentina

Bahrain

Bangladesh

Brazil

Chile

China

Colombia

Egypt

Hong Kong

India

Indonesia

Israel

Jordan

Kuwait

Malaysia

Mauritius

Mexico

Morocco

Nigeria

Global Emerging Markets

Country IMFNext-

11BRICCIVETS FTSE MSCI

THE

ECONOMI

ST

SampPDOW

JONESBBVA

Columbia

University

EMGP

Oman

Pakistan

Peru

Philippines

Qatar

Russia

Saudi Arabia

Singapore

South Africa

South Korea

Sri Lanka

Taiwan

Thailand

Tunisia

Turkey

UAE

Ukraine

Venezuela

Vietnam

Characteristics of GEM Regulatory Agencies

Many markets expect a major market (eg US or EMA)

approval before filing

- This facilitates approval in these countries

- Notable exceptions South Africa Brazil

Requirements and expertise can vary widely but both

are increasing

- Example Azerbaijan vs Russia vs India

- Example HSA (Singapore)

GEM Challenges

Regulations are evolving

- Advances ICH Pharmaceutical Inspection Coop Scheme

Regulations and guidelines (along with unstated

expectations) are not globally harmonized - Many country or region-specific requirements and interpretation of

guidance

- Pharmacopeia standards differ country to country

- GMPs are not globally harmonized

- Inspections are not globally harmonized

- Differences exist for reviewapproval times clinical trial application

content specification

- Approval of changes is not harmonized

- Post approval reporting requirements are not harmonized

18

GEM Challenges

Increasing complexity with foreign countries

bull Language time zones culture FMAs in-country testing

availability of instrumentation technical savvy

New requirements for some GEM countries

IP issues

Inspections

Multiple approved dossier versions for a single drug

- Multiple specifications multiple item codes different CoAs

different responses to questions

Overall Global CTD not possible

Understanding both the intent and expectations of

questions

19

In-country testing

Many countries require in country testing either before

approval or after launch of the product

Capillary electrophoresis (among other methodologies)

can be a challenge for some markets

Methods need to be robust () to facilitate transfer to

these markets

In-country testing (example)

Country Mandatory Requirement

Small Molecules Biologicals

Full vs Partial testing Local vs Contract Lab

Argentina Yes Yes Full Local Lab mandated

Brazil Yes NA Full Local Lab mandated

Chile Yes Yes Partial is possible Can be contracted out

Uruguay Yes Yes Theoretically full testing selected possible Can be contracted out

Mexico Yes Yes Full Testing (for n=20 batches) Then request a

reduction If tests are too expensive or require

sophisticated equipment reduction is possible

Testing is exempted for orphan drugs

Can be contracted out

Russia Yes Yes Full testing for new registrations Laboratory assigned by

MoH

Turkey Yes Yes Tests performed are based on the product but

normally these include Biological Dissolution

Physical physicochemical controls Content

uniformity amount Microbiological purity and ID

Official analysis institution

of TMOH

Ukraine Yes Yes Full testing State local laboratory

assigned by the MoH

Israel Yes Yes Full testing for the first imported batch and then

upon MoH request

Testing carried out by

MOH Lab

Other countries requiring testing Costa Rica DR El Salvador Ecuador Guatemala Honduras

Nicaragua Panama South Korea etc

GEM Requirements (examples) Brazil (Resolution RDC No 17 16 Apr 2010)

Article 19 Qualification and validation should not be considered only

exercises After the adoption of the qualification andor validation

report it there should have a continuous monitoring program which

must be based on periodic review [Note software validation and re-

validation is called out as a specific self-inspection item]

Article 209 Sole Paragraph Compendial analytical methods do not

require validation but before its implementation there must be

documented evidence of their suitability in the laboratory operating

conditions

Article 312 sect 3 The pharmacopoeial methods should be used for the

validation and performance of the sterility test

Article 463 sect 2 The retrospective validation is no longer encouraged

and is not applicable to the manufacture of sterile products

Article 479 sect 2 A risk assessment should be used to determine the

scope and extent of validation 22

GEM Requirements (examples) Thailand (QampA on ASEAN Analytical Validation)

6 Identify the conditionsscenarios when each of the following is

required to be conducted Full validation Revalidation Verification

Refer to 1 for Full validation and Verification According to ASEAN

Guideline revalidation may be required in the following circumstances

- Change in the synthesis of the drug substance

- Change in the composition of the finished product

- Change in the analytical procedure

From ASEAN Guideline on Analytical Validation (consistent with ICH)

The compendial methods are not required to be validated but merely

verify their suitability under actual conditions of use

23

GEM Requirements (examples) ASEAN Variation Guideline for Pharmaceutical

Products

Major Variation

- No analytical examples (not counting specification changes)

Minor Variation - Prior Approval (MiV-PA)

- Change of test procedure to non-compendial drug substance (must at

least show equivalence to former procedure) ndash MiV-PA9

- Change of in-process controls applied during the manufacture of the drug

substance (including tightening and addition of new in-process test) ndash MiV-

PA6

- Change of in-process controls applied during the manufacture of the drug

product (including tightening and addition of new in-process test) ndash MiV-

PA19

bull Interesting note Any new test method does not concern a novel non-standard

technique or a standard technique used in a novel way

Minor Variation - Notification (MiV-N)

- No analytical examples

24

GEM Requirements (examples) South Africa (Amendments)

Four categories

- Type A - amendments that may be implemented without intervention of or prior

notification to Council

- Type B - amendments that require prior notification

- Type C - amendments that require prior approval

- Type D - amendments that should be considered new applications

Type A Biological examples

- (25) Addition of release tests and or of specifications or tightening of

specifications for intermediates of the APIs

Type B Biological examples

- No analytical examples

25

GEM Requirements (examples) South Africa (Amendments)

Type C Biological examples

- (19B) Any change in analytical methods that

bull results in change(s) of specification limits or modification(s) in potency

sensitivity specificity or purity

bull establishes a new analytical method

bull deletes a specification or an analytical method

bull eliminates tests from the stability protocol or

bull alters the acceptance criteria of the stability protocol

- (20B) Any change in production processes that may

bull result in change(s) of specification limits or modification(s) in potency

sensitivity specificity or purity

bull establish a new analytical method

bull delete a specification or an analytical method

bull eliminate tests from the stability protocol or

bull alter the acceptance criteria of the stability protocol

26

Analytical Validation and Method Detail

(several)

Question Asked a series of questions on method details

requested method validation data for all methods used in

the analytical control strategy

Answer

- Provided copies of the methods and answered the specific

detail questions requested

- Some requests have included providing raw data (eg real

weight of reference standard and sample used) from validation

- This detail is requested as a substitute for in-country testing

thus preventing the need for in-country (repeat) testing

- The procedures are not considered ldquopart of the licenserdquo

Result Success

Method detail (South Korea)

Question Detailed test methods for API

Answer

- Provided descriptions of the assays but not copies of the methods

- These are not considered ldquopart of the licenserdquo (eg The detailed test

methods for Drug Substance are supplied as a reference The

information provided in Module 3 Section 32S42 Analytical

Procedures is considered to contain the regulatory information and

requirements)

Result Success

Detailed data (several)

Question Provide chromatograms and electropherograms for all

stability timepoints

Answer

- Provided chromatogramselectropherograms sometimes providing only

one lot instead of three lots

Result Success

Conclusions

Understanding analytical methods including real time

assessments of variability are becoming increasingly

important

The trends toward increased globalization will create

additional work and challenge for analytical professionals

Global Emerging Markets will become a larger portion of

the work due to increasing complexity in these markets

Acknowledgements

Catherine Anderson

Helena Madden

Sue Stella

Guidance list (non-inclusive) Region Topic ASEAN ASEAN GUIDELINE ON SUBMISSION OF MANUFACTURING PROCESS VALIDATION DATA FOR DRUG REGISTRATION

httpwwwhsagovsgpublishetcmedialibhsa_libraryhealth_products_regulationwestern_medicinesfiles_guidelinesPar96657FiledatA

SEAN20PV20(Version2031)20Main20Guide20without20annexespdf ASEAN VARIATION GUIDELINE FOR PHARMACEUTICAL PRODUCTS

httpwwwfdagovphattachmentsarticle95567ASEAN20Variation20Guideline20for20Pharmaceutical20Products20Final20

Draft207220(2013)pdf Thailand QampA on ASEAN Analytical Validation

httpwwwhsagovsgpublishetcmedialibhsa_libraryhealth_products_regulationwestern_medicinesfiles_guidelinesPar98887FiledatQ

ampA20analytical20validation-25jun55pdf ASEAN website with links to several guidances

httpwwwaseanorgcommunitiesasean-economic-communityitemharmonization-of-standards-and-technical-requirements-in-asean Brazil Resolution RDC No 27

httpwwwemergogroupcomfilesbrazil-resolution-rdc-no-27-21-june-2011pdf

Establishes Minimum Requirements for the Validation of Bioanalytical Methods Used in Pre- and Post-Marketing Studies

The validation of the analytical methods (Resolution RE 899 (IDRAC 39212) of 29-May-20033 and Resolution RDC 27 (IDRAC 143541) of

17-May-2012) is mandatory whenever the method is an in-house method or it is not described in pharmacopeias accepted by ANVISA Resolution RDC No 17

httpwwwabiquifiorgbrlegislacaoanvisaingles_rdc17pdf

16-Apr-2010 presents detailed guidelines about the validation and qualification requirements in the pharmaceutical industry as part of the

Good Manufacturing Practices Regulation Australia Note for Guidance on Validation of Analytical Procedures Text and Methodology

CPMPICH38195 (pdf183kb)

Japan Excerpt from presentation Japan has no guidance for bioanalytical method validation The answers in these slides are the results of the

discussion in the JBF kickoff meeting on March 30 (2011)1048579

httpwwwnihsgojpdrugBMVMontreal20110414_katoripdf Malaysia httpportalbpfkgovmyaeimagesFileAnalytical_Validation_Documents_of_Injections_Submission_Guidelinespdf Singapore ANALYTICAL METHOD VALIDATION

httpwwwhsagovsgpublishetcmedialibhsa_libraryhealth_products_regulationgmpfiles_1Par23186FiledatGUIDE-MQA-012A-

004pdf

Page 8: Capillary Electrophoresis in Global Emerging Markets: …c.ymcdn.com/sites/casss.site-ym.com/resource/resmgr/CE_Pharm...manufacturing process, ... From ASEAN Guideline on Analytical

Understanding variability

Variability comes in three

forms process sample

and analytical

A control chart of the lot

release values will

encompass all three forms

of variability

It is rare that all three types

can be accurately

quantitated without a

carefully planned and

executed hierarchical or

similar study

σsup2 = σsup2P + σsup2S + σsup2T

Where

σsup2 = Total variance

σsup2P = Process variance

σsup2S = Sampling variance

σsup2T = Test variance

Illustrating Stability

0

2

4

6

8

10

12

14

0 5 10 15 20 25 30 35 40 45 50

If the points fall at random about the centreline

and remain within the control limits the

process is deemed to be stable

Illustrating Instability

0

2

4

6

8

10

12

14

16

18

20

0 5 10 15 20 25 30 35 40 45 50

If this red line is the test specification

should we react to the ldquospecial causerdquo

A better way

0

2

4

6

8

10

12

14

16

18

20

0 5 10 15 20 25 30 35 40 45 500

2

4

6

8

10

12

14

16

18

20

0 5 10 15 20 25 30 35 40 45 50

Re-drawing the limits makes it easy to see

17

18

19

20

21

22

23

24

25

26

27

1 4 7 10 13 16 19 22 25 28 31 34 37 40 43

15

17

19

21

23

25

27

29

31

33

35

1 4 7 10

13

16

19

22

25

28

31

34

37

40

43

Production Data Laboratory Controls

Where Lies The Problem Limits are set as per the usual practice plusmn 3 sigma

Understanding the data

18

19

20

21

22

23

24

25

26

0 5 10 15 20 25 30 35 40 45 50

1-P

oint

Ave

rage

0

05

1

15

2

25

3

35

4

45

5

Ran

ge

20

22

24

26

28

30

32

34

0 5 10 15 20 25 30 35 40 45 50

1-P

oint

Ave

rage

0

2

4

6

8

10

12

Ran

ge

Understanding the data

Shewhart Control Charts are Usedhellip

Global Emerging Markets

For most life cycle management activites focus on the

ldquoreferencerdquo markets eg US EMA Canada Japan

There are of course hundreds of other markets

The prominent and fast growing are referred to as Global

Emerging Markets

These markets are becoming strategically important for

the pharmaceutical industry

Global Emerging Markets

Country IMFNext-

11BRICCIVETS FTSE MSCI

THE

ECONOMI

ST

SampPDOW

JONESBBVA

Columbia

University

EMGP

Argentina

Bahrain

Bangladesh

Brazil

Chile

China

Colombia

Egypt

Hong Kong

India

Indonesia

Israel

Jordan

Kuwait

Malaysia

Mauritius

Mexico

Morocco

Nigeria

Global Emerging Markets

Country IMFNext-

11BRICCIVETS FTSE MSCI

THE

ECONOMI

ST

SampPDOW

JONESBBVA

Columbia

University

EMGP

Oman

Pakistan

Peru

Philippines

Qatar

Russia

Saudi Arabia

Singapore

South Africa

South Korea

Sri Lanka

Taiwan

Thailand

Tunisia

Turkey

UAE

Ukraine

Venezuela

Vietnam

Characteristics of GEM Regulatory Agencies

Many markets expect a major market (eg US or EMA)

approval before filing

- This facilitates approval in these countries

- Notable exceptions South Africa Brazil

Requirements and expertise can vary widely but both

are increasing

- Example Azerbaijan vs Russia vs India

- Example HSA (Singapore)

GEM Challenges

Regulations are evolving

- Advances ICH Pharmaceutical Inspection Coop Scheme

Regulations and guidelines (along with unstated

expectations) are not globally harmonized - Many country or region-specific requirements and interpretation of

guidance

- Pharmacopeia standards differ country to country

- GMPs are not globally harmonized

- Inspections are not globally harmonized

- Differences exist for reviewapproval times clinical trial application

content specification

- Approval of changes is not harmonized

- Post approval reporting requirements are not harmonized

18

GEM Challenges

Increasing complexity with foreign countries

bull Language time zones culture FMAs in-country testing

availability of instrumentation technical savvy

New requirements for some GEM countries

IP issues

Inspections

Multiple approved dossier versions for a single drug

- Multiple specifications multiple item codes different CoAs

different responses to questions

Overall Global CTD not possible

Understanding both the intent and expectations of

questions

19

In-country testing

Many countries require in country testing either before

approval or after launch of the product

Capillary electrophoresis (among other methodologies)

can be a challenge for some markets

Methods need to be robust () to facilitate transfer to

these markets

In-country testing (example)

Country Mandatory Requirement

Small Molecules Biologicals

Full vs Partial testing Local vs Contract Lab

Argentina Yes Yes Full Local Lab mandated

Brazil Yes NA Full Local Lab mandated

Chile Yes Yes Partial is possible Can be contracted out

Uruguay Yes Yes Theoretically full testing selected possible Can be contracted out

Mexico Yes Yes Full Testing (for n=20 batches) Then request a

reduction If tests are too expensive or require

sophisticated equipment reduction is possible

Testing is exempted for orphan drugs

Can be contracted out

Russia Yes Yes Full testing for new registrations Laboratory assigned by

MoH

Turkey Yes Yes Tests performed are based on the product but

normally these include Biological Dissolution

Physical physicochemical controls Content

uniformity amount Microbiological purity and ID

Official analysis institution

of TMOH

Ukraine Yes Yes Full testing State local laboratory

assigned by the MoH

Israel Yes Yes Full testing for the first imported batch and then

upon MoH request

Testing carried out by

MOH Lab

Other countries requiring testing Costa Rica DR El Salvador Ecuador Guatemala Honduras

Nicaragua Panama South Korea etc

GEM Requirements (examples) Brazil (Resolution RDC No 17 16 Apr 2010)

Article 19 Qualification and validation should not be considered only

exercises After the adoption of the qualification andor validation

report it there should have a continuous monitoring program which

must be based on periodic review [Note software validation and re-

validation is called out as a specific self-inspection item]

Article 209 Sole Paragraph Compendial analytical methods do not

require validation but before its implementation there must be

documented evidence of their suitability in the laboratory operating

conditions

Article 312 sect 3 The pharmacopoeial methods should be used for the

validation and performance of the sterility test

Article 463 sect 2 The retrospective validation is no longer encouraged

and is not applicable to the manufacture of sterile products

Article 479 sect 2 A risk assessment should be used to determine the

scope and extent of validation 22

GEM Requirements (examples) Thailand (QampA on ASEAN Analytical Validation)

6 Identify the conditionsscenarios when each of the following is

required to be conducted Full validation Revalidation Verification

Refer to 1 for Full validation and Verification According to ASEAN

Guideline revalidation may be required in the following circumstances

- Change in the synthesis of the drug substance

- Change in the composition of the finished product

- Change in the analytical procedure

From ASEAN Guideline on Analytical Validation (consistent with ICH)

The compendial methods are not required to be validated but merely

verify their suitability under actual conditions of use

23

GEM Requirements (examples) ASEAN Variation Guideline for Pharmaceutical

Products

Major Variation

- No analytical examples (not counting specification changes)

Minor Variation - Prior Approval (MiV-PA)

- Change of test procedure to non-compendial drug substance (must at

least show equivalence to former procedure) ndash MiV-PA9

- Change of in-process controls applied during the manufacture of the drug

substance (including tightening and addition of new in-process test) ndash MiV-

PA6

- Change of in-process controls applied during the manufacture of the drug

product (including tightening and addition of new in-process test) ndash MiV-

PA19

bull Interesting note Any new test method does not concern a novel non-standard

technique or a standard technique used in a novel way

Minor Variation - Notification (MiV-N)

- No analytical examples

24

GEM Requirements (examples) South Africa (Amendments)

Four categories

- Type A - amendments that may be implemented without intervention of or prior

notification to Council

- Type B - amendments that require prior notification

- Type C - amendments that require prior approval

- Type D - amendments that should be considered new applications

Type A Biological examples

- (25) Addition of release tests and or of specifications or tightening of

specifications for intermediates of the APIs

Type B Biological examples

- No analytical examples

25

GEM Requirements (examples) South Africa (Amendments)

Type C Biological examples

- (19B) Any change in analytical methods that

bull results in change(s) of specification limits or modification(s) in potency

sensitivity specificity or purity

bull establishes a new analytical method

bull deletes a specification or an analytical method

bull eliminates tests from the stability protocol or

bull alters the acceptance criteria of the stability protocol

- (20B) Any change in production processes that may

bull result in change(s) of specification limits or modification(s) in potency

sensitivity specificity or purity

bull establish a new analytical method

bull delete a specification or an analytical method

bull eliminate tests from the stability protocol or

bull alter the acceptance criteria of the stability protocol

26

Analytical Validation and Method Detail

(several)

Question Asked a series of questions on method details

requested method validation data for all methods used in

the analytical control strategy

Answer

- Provided copies of the methods and answered the specific

detail questions requested

- Some requests have included providing raw data (eg real

weight of reference standard and sample used) from validation

- This detail is requested as a substitute for in-country testing

thus preventing the need for in-country (repeat) testing

- The procedures are not considered ldquopart of the licenserdquo

Result Success

Method detail (South Korea)

Question Detailed test methods for API

Answer

- Provided descriptions of the assays but not copies of the methods

- These are not considered ldquopart of the licenserdquo (eg The detailed test

methods for Drug Substance are supplied as a reference The

information provided in Module 3 Section 32S42 Analytical

Procedures is considered to contain the regulatory information and

requirements)

Result Success

Detailed data (several)

Question Provide chromatograms and electropherograms for all

stability timepoints

Answer

- Provided chromatogramselectropherograms sometimes providing only

one lot instead of three lots

Result Success

Conclusions

Understanding analytical methods including real time

assessments of variability are becoming increasingly

important

The trends toward increased globalization will create

additional work and challenge for analytical professionals

Global Emerging Markets will become a larger portion of

the work due to increasing complexity in these markets

Acknowledgements

Catherine Anderson

Helena Madden

Sue Stella

Guidance list (non-inclusive) Region Topic ASEAN ASEAN GUIDELINE ON SUBMISSION OF MANUFACTURING PROCESS VALIDATION DATA FOR DRUG REGISTRATION

httpwwwhsagovsgpublishetcmedialibhsa_libraryhealth_products_regulationwestern_medicinesfiles_guidelinesPar96657FiledatA

SEAN20PV20(Version2031)20Main20Guide20without20annexespdf ASEAN VARIATION GUIDELINE FOR PHARMACEUTICAL PRODUCTS

httpwwwfdagovphattachmentsarticle95567ASEAN20Variation20Guideline20for20Pharmaceutical20Products20Final20

Draft207220(2013)pdf Thailand QampA on ASEAN Analytical Validation

httpwwwhsagovsgpublishetcmedialibhsa_libraryhealth_products_regulationwestern_medicinesfiles_guidelinesPar98887FiledatQ

ampA20analytical20validation-25jun55pdf ASEAN website with links to several guidances

httpwwwaseanorgcommunitiesasean-economic-communityitemharmonization-of-standards-and-technical-requirements-in-asean Brazil Resolution RDC No 27

httpwwwemergogroupcomfilesbrazil-resolution-rdc-no-27-21-june-2011pdf

Establishes Minimum Requirements for the Validation of Bioanalytical Methods Used in Pre- and Post-Marketing Studies

The validation of the analytical methods (Resolution RE 899 (IDRAC 39212) of 29-May-20033 and Resolution RDC 27 (IDRAC 143541) of

17-May-2012) is mandatory whenever the method is an in-house method or it is not described in pharmacopeias accepted by ANVISA Resolution RDC No 17

httpwwwabiquifiorgbrlegislacaoanvisaingles_rdc17pdf

16-Apr-2010 presents detailed guidelines about the validation and qualification requirements in the pharmaceutical industry as part of the

Good Manufacturing Practices Regulation Australia Note for Guidance on Validation of Analytical Procedures Text and Methodology

CPMPICH38195 (pdf183kb)

Japan Excerpt from presentation Japan has no guidance for bioanalytical method validation The answers in these slides are the results of the

discussion in the JBF kickoff meeting on March 30 (2011)1048579

httpwwwnihsgojpdrugBMVMontreal20110414_katoripdf Malaysia httpportalbpfkgovmyaeimagesFileAnalytical_Validation_Documents_of_Injections_Submission_Guidelinespdf Singapore ANALYTICAL METHOD VALIDATION

httpwwwhsagovsgpublishetcmedialibhsa_libraryhealth_products_regulationgmpfiles_1Par23186FiledatGUIDE-MQA-012A-

004pdf

Page 9: Capillary Electrophoresis in Global Emerging Markets: …c.ymcdn.com/sites/casss.site-ym.com/resource/resmgr/CE_Pharm...manufacturing process, ... From ASEAN Guideline on Analytical

Illustrating Stability

0

2

4

6

8

10

12

14

0 5 10 15 20 25 30 35 40 45 50

If the points fall at random about the centreline

and remain within the control limits the

process is deemed to be stable

Illustrating Instability

0

2

4

6

8

10

12

14

16

18

20

0 5 10 15 20 25 30 35 40 45 50

If this red line is the test specification

should we react to the ldquospecial causerdquo

A better way

0

2

4

6

8

10

12

14

16

18

20

0 5 10 15 20 25 30 35 40 45 500

2

4

6

8

10

12

14

16

18

20

0 5 10 15 20 25 30 35 40 45 50

Re-drawing the limits makes it easy to see

17

18

19

20

21

22

23

24

25

26

27

1 4 7 10 13 16 19 22 25 28 31 34 37 40 43

15

17

19

21

23

25

27

29

31

33

35

1 4 7 10

13

16

19

22

25

28

31

34

37

40

43

Production Data Laboratory Controls

Where Lies The Problem Limits are set as per the usual practice plusmn 3 sigma

Understanding the data

18

19

20

21

22

23

24

25

26

0 5 10 15 20 25 30 35 40 45 50

1-P

oint

Ave

rage

0

05

1

15

2

25

3

35

4

45

5

Ran

ge

20

22

24

26

28

30

32

34

0 5 10 15 20 25 30 35 40 45 50

1-P

oint

Ave

rage

0

2

4

6

8

10

12

Ran

ge

Understanding the data

Shewhart Control Charts are Usedhellip

Global Emerging Markets

For most life cycle management activites focus on the

ldquoreferencerdquo markets eg US EMA Canada Japan

There are of course hundreds of other markets

The prominent and fast growing are referred to as Global

Emerging Markets

These markets are becoming strategically important for

the pharmaceutical industry

Global Emerging Markets

Country IMFNext-

11BRICCIVETS FTSE MSCI

THE

ECONOMI

ST

SampPDOW

JONESBBVA

Columbia

University

EMGP

Argentina

Bahrain

Bangladesh

Brazil

Chile

China

Colombia

Egypt

Hong Kong

India

Indonesia

Israel

Jordan

Kuwait

Malaysia

Mauritius

Mexico

Morocco

Nigeria

Global Emerging Markets

Country IMFNext-

11BRICCIVETS FTSE MSCI

THE

ECONOMI

ST

SampPDOW

JONESBBVA

Columbia

University

EMGP

Oman

Pakistan

Peru

Philippines

Qatar

Russia

Saudi Arabia

Singapore

South Africa

South Korea

Sri Lanka

Taiwan

Thailand

Tunisia

Turkey

UAE

Ukraine

Venezuela

Vietnam

Characteristics of GEM Regulatory Agencies

Many markets expect a major market (eg US or EMA)

approval before filing

- This facilitates approval in these countries

- Notable exceptions South Africa Brazil

Requirements and expertise can vary widely but both

are increasing

- Example Azerbaijan vs Russia vs India

- Example HSA (Singapore)

GEM Challenges

Regulations are evolving

- Advances ICH Pharmaceutical Inspection Coop Scheme

Regulations and guidelines (along with unstated

expectations) are not globally harmonized - Many country or region-specific requirements and interpretation of

guidance

- Pharmacopeia standards differ country to country

- GMPs are not globally harmonized

- Inspections are not globally harmonized

- Differences exist for reviewapproval times clinical trial application

content specification

- Approval of changes is not harmonized

- Post approval reporting requirements are not harmonized

18

GEM Challenges

Increasing complexity with foreign countries

bull Language time zones culture FMAs in-country testing

availability of instrumentation technical savvy

New requirements for some GEM countries

IP issues

Inspections

Multiple approved dossier versions for a single drug

- Multiple specifications multiple item codes different CoAs

different responses to questions

Overall Global CTD not possible

Understanding both the intent and expectations of

questions

19

In-country testing

Many countries require in country testing either before

approval or after launch of the product

Capillary electrophoresis (among other methodologies)

can be a challenge for some markets

Methods need to be robust () to facilitate transfer to

these markets

In-country testing (example)

Country Mandatory Requirement

Small Molecules Biologicals

Full vs Partial testing Local vs Contract Lab

Argentina Yes Yes Full Local Lab mandated

Brazil Yes NA Full Local Lab mandated

Chile Yes Yes Partial is possible Can be contracted out

Uruguay Yes Yes Theoretically full testing selected possible Can be contracted out

Mexico Yes Yes Full Testing (for n=20 batches) Then request a

reduction If tests are too expensive or require

sophisticated equipment reduction is possible

Testing is exempted for orphan drugs

Can be contracted out

Russia Yes Yes Full testing for new registrations Laboratory assigned by

MoH

Turkey Yes Yes Tests performed are based on the product but

normally these include Biological Dissolution

Physical physicochemical controls Content

uniformity amount Microbiological purity and ID

Official analysis institution

of TMOH

Ukraine Yes Yes Full testing State local laboratory

assigned by the MoH

Israel Yes Yes Full testing for the first imported batch and then

upon MoH request

Testing carried out by

MOH Lab

Other countries requiring testing Costa Rica DR El Salvador Ecuador Guatemala Honduras

Nicaragua Panama South Korea etc

GEM Requirements (examples) Brazil (Resolution RDC No 17 16 Apr 2010)

Article 19 Qualification and validation should not be considered only

exercises After the adoption of the qualification andor validation

report it there should have a continuous monitoring program which

must be based on periodic review [Note software validation and re-

validation is called out as a specific self-inspection item]

Article 209 Sole Paragraph Compendial analytical methods do not

require validation but before its implementation there must be

documented evidence of their suitability in the laboratory operating

conditions

Article 312 sect 3 The pharmacopoeial methods should be used for the

validation and performance of the sterility test

Article 463 sect 2 The retrospective validation is no longer encouraged

and is not applicable to the manufacture of sterile products

Article 479 sect 2 A risk assessment should be used to determine the

scope and extent of validation 22

GEM Requirements (examples) Thailand (QampA on ASEAN Analytical Validation)

6 Identify the conditionsscenarios when each of the following is

required to be conducted Full validation Revalidation Verification

Refer to 1 for Full validation and Verification According to ASEAN

Guideline revalidation may be required in the following circumstances

- Change in the synthesis of the drug substance

- Change in the composition of the finished product

- Change in the analytical procedure

From ASEAN Guideline on Analytical Validation (consistent with ICH)

The compendial methods are not required to be validated but merely

verify their suitability under actual conditions of use

23

GEM Requirements (examples) ASEAN Variation Guideline for Pharmaceutical

Products

Major Variation

- No analytical examples (not counting specification changes)

Minor Variation - Prior Approval (MiV-PA)

- Change of test procedure to non-compendial drug substance (must at

least show equivalence to former procedure) ndash MiV-PA9

- Change of in-process controls applied during the manufacture of the drug

substance (including tightening and addition of new in-process test) ndash MiV-

PA6

- Change of in-process controls applied during the manufacture of the drug

product (including tightening and addition of new in-process test) ndash MiV-

PA19

bull Interesting note Any new test method does not concern a novel non-standard

technique or a standard technique used in a novel way

Minor Variation - Notification (MiV-N)

- No analytical examples

24

GEM Requirements (examples) South Africa (Amendments)

Four categories

- Type A - amendments that may be implemented without intervention of or prior

notification to Council

- Type B - amendments that require prior notification

- Type C - amendments that require prior approval

- Type D - amendments that should be considered new applications

Type A Biological examples

- (25) Addition of release tests and or of specifications or tightening of

specifications for intermediates of the APIs

Type B Biological examples

- No analytical examples

25

GEM Requirements (examples) South Africa (Amendments)

Type C Biological examples

- (19B) Any change in analytical methods that

bull results in change(s) of specification limits or modification(s) in potency

sensitivity specificity or purity

bull establishes a new analytical method

bull deletes a specification or an analytical method

bull eliminates tests from the stability protocol or

bull alters the acceptance criteria of the stability protocol

- (20B) Any change in production processes that may

bull result in change(s) of specification limits or modification(s) in potency

sensitivity specificity or purity

bull establish a new analytical method

bull delete a specification or an analytical method

bull eliminate tests from the stability protocol or

bull alter the acceptance criteria of the stability protocol

26

Analytical Validation and Method Detail

(several)

Question Asked a series of questions on method details

requested method validation data for all methods used in

the analytical control strategy

Answer

- Provided copies of the methods and answered the specific

detail questions requested

- Some requests have included providing raw data (eg real

weight of reference standard and sample used) from validation

- This detail is requested as a substitute for in-country testing

thus preventing the need for in-country (repeat) testing

- The procedures are not considered ldquopart of the licenserdquo

Result Success

Method detail (South Korea)

Question Detailed test methods for API

Answer

- Provided descriptions of the assays but not copies of the methods

- These are not considered ldquopart of the licenserdquo (eg The detailed test

methods for Drug Substance are supplied as a reference The

information provided in Module 3 Section 32S42 Analytical

Procedures is considered to contain the regulatory information and

requirements)

Result Success

Detailed data (several)

Question Provide chromatograms and electropherograms for all

stability timepoints

Answer

- Provided chromatogramselectropherograms sometimes providing only

one lot instead of three lots

Result Success

Conclusions

Understanding analytical methods including real time

assessments of variability are becoming increasingly

important

The trends toward increased globalization will create

additional work and challenge for analytical professionals

Global Emerging Markets will become a larger portion of

the work due to increasing complexity in these markets

Acknowledgements

Catherine Anderson

Helena Madden

Sue Stella

Guidance list (non-inclusive) Region Topic ASEAN ASEAN GUIDELINE ON SUBMISSION OF MANUFACTURING PROCESS VALIDATION DATA FOR DRUG REGISTRATION

httpwwwhsagovsgpublishetcmedialibhsa_libraryhealth_products_regulationwestern_medicinesfiles_guidelinesPar96657FiledatA

SEAN20PV20(Version2031)20Main20Guide20without20annexespdf ASEAN VARIATION GUIDELINE FOR PHARMACEUTICAL PRODUCTS

httpwwwfdagovphattachmentsarticle95567ASEAN20Variation20Guideline20for20Pharmaceutical20Products20Final20

Draft207220(2013)pdf Thailand QampA on ASEAN Analytical Validation

httpwwwhsagovsgpublishetcmedialibhsa_libraryhealth_products_regulationwestern_medicinesfiles_guidelinesPar98887FiledatQ

ampA20analytical20validation-25jun55pdf ASEAN website with links to several guidances

httpwwwaseanorgcommunitiesasean-economic-communityitemharmonization-of-standards-and-technical-requirements-in-asean Brazil Resolution RDC No 27

httpwwwemergogroupcomfilesbrazil-resolution-rdc-no-27-21-june-2011pdf

Establishes Minimum Requirements for the Validation of Bioanalytical Methods Used in Pre- and Post-Marketing Studies

The validation of the analytical methods (Resolution RE 899 (IDRAC 39212) of 29-May-20033 and Resolution RDC 27 (IDRAC 143541) of

17-May-2012) is mandatory whenever the method is an in-house method or it is not described in pharmacopeias accepted by ANVISA Resolution RDC No 17

httpwwwabiquifiorgbrlegislacaoanvisaingles_rdc17pdf

16-Apr-2010 presents detailed guidelines about the validation and qualification requirements in the pharmaceutical industry as part of the

Good Manufacturing Practices Regulation Australia Note for Guidance on Validation of Analytical Procedures Text and Methodology

CPMPICH38195 (pdf183kb)

Japan Excerpt from presentation Japan has no guidance for bioanalytical method validation The answers in these slides are the results of the

discussion in the JBF kickoff meeting on March 30 (2011)1048579

httpwwwnihsgojpdrugBMVMontreal20110414_katoripdf Malaysia httpportalbpfkgovmyaeimagesFileAnalytical_Validation_Documents_of_Injections_Submission_Guidelinespdf Singapore ANALYTICAL METHOD VALIDATION

httpwwwhsagovsgpublishetcmedialibhsa_libraryhealth_products_regulationgmpfiles_1Par23186FiledatGUIDE-MQA-012A-

004pdf

Page 10: Capillary Electrophoresis in Global Emerging Markets: …c.ymcdn.com/sites/casss.site-ym.com/resource/resmgr/CE_Pharm...manufacturing process, ... From ASEAN Guideline on Analytical

Illustrating Instability

0

2

4

6

8

10

12

14

16

18

20

0 5 10 15 20 25 30 35 40 45 50

If this red line is the test specification

should we react to the ldquospecial causerdquo

A better way

0

2

4

6

8

10

12

14

16

18

20

0 5 10 15 20 25 30 35 40 45 500

2

4

6

8

10

12

14

16

18

20

0 5 10 15 20 25 30 35 40 45 50

Re-drawing the limits makes it easy to see

17

18

19

20

21

22

23

24

25

26

27

1 4 7 10 13 16 19 22 25 28 31 34 37 40 43

15

17

19

21

23

25

27

29

31

33

35

1 4 7 10

13

16

19

22

25

28

31

34

37

40

43

Production Data Laboratory Controls

Where Lies The Problem Limits are set as per the usual practice plusmn 3 sigma

Understanding the data

18

19

20

21

22

23

24

25

26

0 5 10 15 20 25 30 35 40 45 50

1-P

oint

Ave

rage

0

05

1

15

2

25

3

35

4

45

5

Ran

ge

20

22

24

26

28

30

32

34

0 5 10 15 20 25 30 35 40 45 50

1-P

oint

Ave

rage

0

2

4

6

8

10

12

Ran

ge

Understanding the data

Shewhart Control Charts are Usedhellip

Global Emerging Markets

For most life cycle management activites focus on the

ldquoreferencerdquo markets eg US EMA Canada Japan

There are of course hundreds of other markets

The prominent and fast growing are referred to as Global

Emerging Markets

These markets are becoming strategically important for

the pharmaceutical industry

Global Emerging Markets

Country IMFNext-

11BRICCIVETS FTSE MSCI

THE

ECONOMI

ST

SampPDOW

JONESBBVA

Columbia

University

EMGP

Argentina

Bahrain

Bangladesh

Brazil

Chile

China

Colombia

Egypt

Hong Kong

India

Indonesia

Israel

Jordan

Kuwait

Malaysia

Mauritius

Mexico

Morocco

Nigeria

Global Emerging Markets

Country IMFNext-

11BRICCIVETS FTSE MSCI

THE

ECONOMI

ST

SampPDOW

JONESBBVA

Columbia

University

EMGP

Oman

Pakistan

Peru

Philippines

Qatar

Russia

Saudi Arabia

Singapore

South Africa

South Korea

Sri Lanka

Taiwan

Thailand

Tunisia

Turkey

UAE

Ukraine

Venezuela

Vietnam

Characteristics of GEM Regulatory Agencies

Many markets expect a major market (eg US or EMA)

approval before filing

- This facilitates approval in these countries

- Notable exceptions South Africa Brazil

Requirements and expertise can vary widely but both

are increasing

- Example Azerbaijan vs Russia vs India

- Example HSA (Singapore)

GEM Challenges

Regulations are evolving

- Advances ICH Pharmaceutical Inspection Coop Scheme

Regulations and guidelines (along with unstated

expectations) are not globally harmonized - Many country or region-specific requirements and interpretation of

guidance

- Pharmacopeia standards differ country to country

- GMPs are not globally harmonized

- Inspections are not globally harmonized

- Differences exist for reviewapproval times clinical trial application

content specification

- Approval of changes is not harmonized

- Post approval reporting requirements are not harmonized

18

GEM Challenges

Increasing complexity with foreign countries

bull Language time zones culture FMAs in-country testing

availability of instrumentation technical savvy

New requirements for some GEM countries

IP issues

Inspections

Multiple approved dossier versions for a single drug

- Multiple specifications multiple item codes different CoAs

different responses to questions

Overall Global CTD not possible

Understanding both the intent and expectations of

questions

19

In-country testing

Many countries require in country testing either before

approval or after launch of the product

Capillary electrophoresis (among other methodologies)

can be a challenge for some markets

Methods need to be robust () to facilitate transfer to

these markets

In-country testing (example)

Country Mandatory Requirement

Small Molecules Biologicals

Full vs Partial testing Local vs Contract Lab

Argentina Yes Yes Full Local Lab mandated

Brazil Yes NA Full Local Lab mandated

Chile Yes Yes Partial is possible Can be contracted out

Uruguay Yes Yes Theoretically full testing selected possible Can be contracted out

Mexico Yes Yes Full Testing (for n=20 batches) Then request a

reduction If tests are too expensive or require

sophisticated equipment reduction is possible

Testing is exempted for orphan drugs

Can be contracted out

Russia Yes Yes Full testing for new registrations Laboratory assigned by

MoH

Turkey Yes Yes Tests performed are based on the product but

normally these include Biological Dissolution

Physical physicochemical controls Content

uniformity amount Microbiological purity and ID

Official analysis institution

of TMOH

Ukraine Yes Yes Full testing State local laboratory

assigned by the MoH

Israel Yes Yes Full testing for the first imported batch and then

upon MoH request

Testing carried out by

MOH Lab

Other countries requiring testing Costa Rica DR El Salvador Ecuador Guatemala Honduras

Nicaragua Panama South Korea etc

GEM Requirements (examples) Brazil (Resolution RDC No 17 16 Apr 2010)

Article 19 Qualification and validation should not be considered only

exercises After the adoption of the qualification andor validation

report it there should have a continuous monitoring program which

must be based on periodic review [Note software validation and re-

validation is called out as a specific self-inspection item]

Article 209 Sole Paragraph Compendial analytical methods do not

require validation but before its implementation there must be

documented evidence of their suitability in the laboratory operating

conditions

Article 312 sect 3 The pharmacopoeial methods should be used for the

validation and performance of the sterility test

Article 463 sect 2 The retrospective validation is no longer encouraged

and is not applicable to the manufacture of sterile products

Article 479 sect 2 A risk assessment should be used to determine the

scope and extent of validation 22

GEM Requirements (examples) Thailand (QampA on ASEAN Analytical Validation)

6 Identify the conditionsscenarios when each of the following is

required to be conducted Full validation Revalidation Verification

Refer to 1 for Full validation and Verification According to ASEAN

Guideline revalidation may be required in the following circumstances

- Change in the synthesis of the drug substance

- Change in the composition of the finished product

- Change in the analytical procedure

From ASEAN Guideline on Analytical Validation (consistent with ICH)

The compendial methods are not required to be validated but merely

verify their suitability under actual conditions of use

23

GEM Requirements (examples) ASEAN Variation Guideline for Pharmaceutical

Products

Major Variation

- No analytical examples (not counting specification changes)

Minor Variation - Prior Approval (MiV-PA)

- Change of test procedure to non-compendial drug substance (must at

least show equivalence to former procedure) ndash MiV-PA9

- Change of in-process controls applied during the manufacture of the drug

substance (including tightening and addition of new in-process test) ndash MiV-

PA6

- Change of in-process controls applied during the manufacture of the drug

product (including tightening and addition of new in-process test) ndash MiV-

PA19

bull Interesting note Any new test method does not concern a novel non-standard

technique or a standard technique used in a novel way

Minor Variation - Notification (MiV-N)

- No analytical examples

24

GEM Requirements (examples) South Africa (Amendments)

Four categories

- Type A - amendments that may be implemented without intervention of or prior

notification to Council

- Type B - amendments that require prior notification

- Type C - amendments that require prior approval

- Type D - amendments that should be considered new applications

Type A Biological examples

- (25) Addition of release tests and or of specifications or tightening of

specifications for intermediates of the APIs

Type B Biological examples

- No analytical examples

25

GEM Requirements (examples) South Africa (Amendments)

Type C Biological examples

- (19B) Any change in analytical methods that

bull results in change(s) of specification limits or modification(s) in potency

sensitivity specificity or purity

bull establishes a new analytical method

bull deletes a specification or an analytical method

bull eliminates tests from the stability protocol or

bull alters the acceptance criteria of the stability protocol

- (20B) Any change in production processes that may

bull result in change(s) of specification limits or modification(s) in potency

sensitivity specificity or purity

bull establish a new analytical method

bull delete a specification or an analytical method

bull eliminate tests from the stability protocol or

bull alter the acceptance criteria of the stability protocol

26

Analytical Validation and Method Detail

(several)

Question Asked a series of questions on method details

requested method validation data for all methods used in

the analytical control strategy

Answer

- Provided copies of the methods and answered the specific

detail questions requested

- Some requests have included providing raw data (eg real

weight of reference standard and sample used) from validation

- This detail is requested as a substitute for in-country testing

thus preventing the need for in-country (repeat) testing

- The procedures are not considered ldquopart of the licenserdquo

Result Success

Method detail (South Korea)

Question Detailed test methods for API

Answer

- Provided descriptions of the assays but not copies of the methods

- These are not considered ldquopart of the licenserdquo (eg The detailed test

methods for Drug Substance are supplied as a reference The

information provided in Module 3 Section 32S42 Analytical

Procedures is considered to contain the regulatory information and

requirements)

Result Success

Detailed data (several)

Question Provide chromatograms and electropherograms for all

stability timepoints

Answer

- Provided chromatogramselectropherograms sometimes providing only

one lot instead of three lots

Result Success

Conclusions

Understanding analytical methods including real time

assessments of variability are becoming increasingly

important

The trends toward increased globalization will create

additional work and challenge for analytical professionals

Global Emerging Markets will become a larger portion of

the work due to increasing complexity in these markets

Acknowledgements

Catherine Anderson

Helena Madden

Sue Stella

Guidance list (non-inclusive) Region Topic ASEAN ASEAN GUIDELINE ON SUBMISSION OF MANUFACTURING PROCESS VALIDATION DATA FOR DRUG REGISTRATION

httpwwwhsagovsgpublishetcmedialibhsa_libraryhealth_products_regulationwestern_medicinesfiles_guidelinesPar96657FiledatA

SEAN20PV20(Version2031)20Main20Guide20without20annexespdf ASEAN VARIATION GUIDELINE FOR PHARMACEUTICAL PRODUCTS

httpwwwfdagovphattachmentsarticle95567ASEAN20Variation20Guideline20for20Pharmaceutical20Products20Final20

Draft207220(2013)pdf Thailand QampA on ASEAN Analytical Validation

httpwwwhsagovsgpublishetcmedialibhsa_libraryhealth_products_regulationwestern_medicinesfiles_guidelinesPar98887FiledatQ

ampA20analytical20validation-25jun55pdf ASEAN website with links to several guidances

httpwwwaseanorgcommunitiesasean-economic-communityitemharmonization-of-standards-and-technical-requirements-in-asean Brazil Resolution RDC No 27

httpwwwemergogroupcomfilesbrazil-resolution-rdc-no-27-21-june-2011pdf

Establishes Minimum Requirements for the Validation of Bioanalytical Methods Used in Pre- and Post-Marketing Studies

The validation of the analytical methods (Resolution RE 899 (IDRAC 39212) of 29-May-20033 and Resolution RDC 27 (IDRAC 143541) of

17-May-2012) is mandatory whenever the method is an in-house method or it is not described in pharmacopeias accepted by ANVISA Resolution RDC No 17

httpwwwabiquifiorgbrlegislacaoanvisaingles_rdc17pdf

16-Apr-2010 presents detailed guidelines about the validation and qualification requirements in the pharmaceutical industry as part of the

Good Manufacturing Practices Regulation Australia Note for Guidance on Validation of Analytical Procedures Text and Methodology

CPMPICH38195 (pdf183kb)

Japan Excerpt from presentation Japan has no guidance for bioanalytical method validation The answers in these slides are the results of the

discussion in the JBF kickoff meeting on March 30 (2011)1048579

httpwwwnihsgojpdrugBMVMontreal20110414_katoripdf Malaysia httpportalbpfkgovmyaeimagesFileAnalytical_Validation_Documents_of_Injections_Submission_Guidelinespdf Singapore ANALYTICAL METHOD VALIDATION

httpwwwhsagovsgpublishetcmedialibhsa_libraryhealth_products_regulationgmpfiles_1Par23186FiledatGUIDE-MQA-012A-

004pdf

Page 11: Capillary Electrophoresis in Global Emerging Markets: …c.ymcdn.com/sites/casss.site-ym.com/resource/resmgr/CE_Pharm...manufacturing process, ... From ASEAN Guideline on Analytical

A better way

0

2

4

6

8

10

12

14

16

18

20

0 5 10 15 20 25 30 35 40 45 500

2

4

6

8

10

12

14

16

18

20

0 5 10 15 20 25 30 35 40 45 50

Re-drawing the limits makes it easy to see

17

18

19

20

21

22

23

24

25

26

27

1 4 7 10 13 16 19 22 25 28 31 34 37 40 43

15

17

19

21

23

25

27

29

31

33

35

1 4 7 10

13

16

19

22

25

28

31

34

37

40

43

Production Data Laboratory Controls

Where Lies The Problem Limits are set as per the usual practice plusmn 3 sigma

Understanding the data

18

19

20

21

22

23

24

25

26

0 5 10 15 20 25 30 35 40 45 50

1-P

oint

Ave

rage

0

05

1

15

2

25

3

35

4

45

5

Ran

ge

20

22

24

26

28

30

32

34

0 5 10 15 20 25 30 35 40 45 50

1-P

oint

Ave

rage

0

2

4

6

8

10

12

Ran

ge

Understanding the data

Shewhart Control Charts are Usedhellip

Global Emerging Markets

For most life cycle management activites focus on the

ldquoreferencerdquo markets eg US EMA Canada Japan

There are of course hundreds of other markets

The prominent and fast growing are referred to as Global

Emerging Markets

These markets are becoming strategically important for

the pharmaceutical industry

Global Emerging Markets

Country IMFNext-

11BRICCIVETS FTSE MSCI

THE

ECONOMI

ST

SampPDOW

JONESBBVA

Columbia

University

EMGP

Argentina

Bahrain

Bangladesh

Brazil

Chile

China

Colombia

Egypt

Hong Kong

India

Indonesia

Israel

Jordan

Kuwait

Malaysia

Mauritius

Mexico

Morocco

Nigeria

Global Emerging Markets

Country IMFNext-

11BRICCIVETS FTSE MSCI

THE

ECONOMI

ST

SampPDOW

JONESBBVA

Columbia

University

EMGP

Oman

Pakistan

Peru

Philippines

Qatar

Russia

Saudi Arabia

Singapore

South Africa

South Korea

Sri Lanka

Taiwan

Thailand

Tunisia

Turkey

UAE

Ukraine

Venezuela

Vietnam

Characteristics of GEM Regulatory Agencies

Many markets expect a major market (eg US or EMA)

approval before filing

- This facilitates approval in these countries

- Notable exceptions South Africa Brazil

Requirements and expertise can vary widely but both

are increasing

- Example Azerbaijan vs Russia vs India

- Example HSA (Singapore)

GEM Challenges

Regulations are evolving

- Advances ICH Pharmaceutical Inspection Coop Scheme

Regulations and guidelines (along with unstated

expectations) are not globally harmonized - Many country or region-specific requirements and interpretation of

guidance

- Pharmacopeia standards differ country to country

- GMPs are not globally harmonized

- Inspections are not globally harmonized

- Differences exist for reviewapproval times clinical trial application

content specification

- Approval of changes is not harmonized

- Post approval reporting requirements are not harmonized

18

GEM Challenges

Increasing complexity with foreign countries

bull Language time zones culture FMAs in-country testing

availability of instrumentation technical savvy

New requirements for some GEM countries

IP issues

Inspections

Multiple approved dossier versions for a single drug

- Multiple specifications multiple item codes different CoAs

different responses to questions

Overall Global CTD not possible

Understanding both the intent and expectations of

questions

19

In-country testing

Many countries require in country testing either before

approval or after launch of the product

Capillary electrophoresis (among other methodologies)

can be a challenge for some markets

Methods need to be robust () to facilitate transfer to

these markets

In-country testing (example)

Country Mandatory Requirement

Small Molecules Biologicals

Full vs Partial testing Local vs Contract Lab

Argentina Yes Yes Full Local Lab mandated

Brazil Yes NA Full Local Lab mandated

Chile Yes Yes Partial is possible Can be contracted out

Uruguay Yes Yes Theoretically full testing selected possible Can be contracted out

Mexico Yes Yes Full Testing (for n=20 batches) Then request a

reduction If tests are too expensive or require

sophisticated equipment reduction is possible

Testing is exempted for orphan drugs

Can be contracted out

Russia Yes Yes Full testing for new registrations Laboratory assigned by

MoH

Turkey Yes Yes Tests performed are based on the product but

normally these include Biological Dissolution

Physical physicochemical controls Content

uniformity amount Microbiological purity and ID

Official analysis institution

of TMOH

Ukraine Yes Yes Full testing State local laboratory

assigned by the MoH

Israel Yes Yes Full testing for the first imported batch and then

upon MoH request

Testing carried out by

MOH Lab

Other countries requiring testing Costa Rica DR El Salvador Ecuador Guatemala Honduras

Nicaragua Panama South Korea etc

GEM Requirements (examples) Brazil (Resolution RDC No 17 16 Apr 2010)

Article 19 Qualification and validation should not be considered only

exercises After the adoption of the qualification andor validation

report it there should have a continuous monitoring program which

must be based on periodic review [Note software validation and re-

validation is called out as a specific self-inspection item]

Article 209 Sole Paragraph Compendial analytical methods do not

require validation but before its implementation there must be

documented evidence of their suitability in the laboratory operating

conditions

Article 312 sect 3 The pharmacopoeial methods should be used for the

validation and performance of the sterility test

Article 463 sect 2 The retrospective validation is no longer encouraged

and is not applicable to the manufacture of sterile products

Article 479 sect 2 A risk assessment should be used to determine the

scope and extent of validation 22

GEM Requirements (examples) Thailand (QampA on ASEAN Analytical Validation)

6 Identify the conditionsscenarios when each of the following is

required to be conducted Full validation Revalidation Verification

Refer to 1 for Full validation and Verification According to ASEAN

Guideline revalidation may be required in the following circumstances

- Change in the synthesis of the drug substance

- Change in the composition of the finished product

- Change in the analytical procedure

From ASEAN Guideline on Analytical Validation (consistent with ICH)

The compendial methods are not required to be validated but merely

verify their suitability under actual conditions of use

23

GEM Requirements (examples) ASEAN Variation Guideline for Pharmaceutical

Products

Major Variation

- No analytical examples (not counting specification changes)

Minor Variation - Prior Approval (MiV-PA)

- Change of test procedure to non-compendial drug substance (must at

least show equivalence to former procedure) ndash MiV-PA9

- Change of in-process controls applied during the manufacture of the drug

substance (including tightening and addition of new in-process test) ndash MiV-

PA6

- Change of in-process controls applied during the manufacture of the drug

product (including tightening and addition of new in-process test) ndash MiV-

PA19

bull Interesting note Any new test method does not concern a novel non-standard

technique or a standard technique used in a novel way

Minor Variation - Notification (MiV-N)

- No analytical examples

24

GEM Requirements (examples) South Africa (Amendments)

Four categories

- Type A - amendments that may be implemented without intervention of or prior

notification to Council

- Type B - amendments that require prior notification

- Type C - amendments that require prior approval

- Type D - amendments that should be considered new applications

Type A Biological examples

- (25) Addition of release tests and or of specifications or tightening of

specifications for intermediates of the APIs

Type B Biological examples

- No analytical examples

25

GEM Requirements (examples) South Africa (Amendments)

Type C Biological examples

- (19B) Any change in analytical methods that

bull results in change(s) of specification limits or modification(s) in potency

sensitivity specificity or purity

bull establishes a new analytical method

bull deletes a specification or an analytical method

bull eliminates tests from the stability protocol or

bull alters the acceptance criteria of the stability protocol

- (20B) Any change in production processes that may

bull result in change(s) of specification limits or modification(s) in potency

sensitivity specificity or purity

bull establish a new analytical method

bull delete a specification or an analytical method

bull eliminate tests from the stability protocol or

bull alter the acceptance criteria of the stability protocol

26

Analytical Validation and Method Detail

(several)

Question Asked a series of questions on method details

requested method validation data for all methods used in

the analytical control strategy

Answer

- Provided copies of the methods and answered the specific

detail questions requested

- Some requests have included providing raw data (eg real

weight of reference standard and sample used) from validation

- This detail is requested as a substitute for in-country testing

thus preventing the need for in-country (repeat) testing

- The procedures are not considered ldquopart of the licenserdquo

Result Success

Method detail (South Korea)

Question Detailed test methods for API

Answer

- Provided descriptions of the assays but not copies of the methods

- These are not considered ldquopart of the licenserdquo (eg The detailed test

methods for Drug Substance are supplied as a reference The

information provided in Module 3 Section 32S42 Analytical

Procedures is considered to contain the regulatory information and

requirements)

Result Success

Detailed data (several)

Question Provide chromatograms and electropherograms for all

stability timepoints

Answer

- Provided chromatogramselectropherograms sometimes providing only

one lot instead of three lots

Result Success

Conclusions

Understanding analytical methods including real time

assessments of variability are becoming increasingly

important

The trends toward increased globalization will create

additional work and challenge for analytical professionals

Global Emerging Markets will become a larger portion of

the work due to increasing complexity in these markets

Acknowledgements

Catherine Anderson

Helena Madden

Sue Stella

Guidance list (non-inclusive) Region Topic ASEAN ASEAN GUIDELINE ON SUBMISSION OF MANUFACTURING PROCESS VALIDATION DATA FOR DRUG REGISTRATION

httpwwwhsagovsgpublishetcmedialibhsa_libraryhealth_products_regulationwestern_medicinesfiles_guidelinesPar96657FiledatA

SEAN20PV20(Version2031)20Main20Guide20without20annexespdf ASEAN VARIATION GUIDELINE FOR PHARMACEUTICAL PRODUCTS

httpwwwfdagovphattachmentsarticle95567ASEAN20Variation20Guideline20for20Pharmaceutical20Products20Final20

Draft207220(2013)pdf Thailand QampA on ASEAN Analytical Validation

httpwwwhsagovsgpublishetcmedialibhsa_libraryhealth_products_regulationwestern_medicinesfiles_guidelinesPar98887FiledatQ

ampA20analytical20validation-25jun55pdf ASEAN website with links to several guidances

httpwwwaseanorgcommunitiesasean-economic-communityitemharmonization-of-standards-and-technical-requirements-in-asean Brazil Resolution RDC No 27

httpwwwemergogroupcomfilesbrazil-resolution-rdc-no-27-21-june-2011pdf

Establishes Minimum Requirements for the Validation of Bioanalytical Methods Used in Pre- and Post-Marketing Studies

The validation of the analytical methods (Resolution RE 899 (IDRAC 39212) of 29-May-20033 and Resolution RDC 27 (IDRAC 143541) of

17-May-2012) is mandatory whenever the method is an in-house method or it is not described in pharmacopeias accepted by ANVISA Resolution RDC No 17

httpwwwabiquifiorgbrlegislacaoanvisaingles_rdc17pdf

16-Apr-2010 presents detailed guidelines about the validation and qualification requirements in the pharmaceutical industry as part of the

Good Manufacturing Practices Regulation Australia Note for Guidance on Validation of Analytical Procedures Text and Methodology

CPMPICH38195 (pdf183kb)

Japan Excerpt from presentation Japan has no guidance for bioanalytical method validation The answers in these slides are the results of the

discussion in the JBF kickoff meeting on March 30 (2011)1048579

httpwwwnihsgojpdrugBMVMontreal20110414_katoripdf Malaysia httpportalbpfkgovmyaeimagesFileAnalytical_Validation_Documents_of_Injections_Submission_Guidelinespdf Singapore ANALYTICAL METHOD VALIDATION

httpwwwhsagovsgpublishetcmedialibhsa_libraryhealth_products_regulationgmpfiles_1Par23186FiledatGUIDE-MQA-012A-

004pdf

Page 12: Capillary Electrophoresis in Global Emerging Markets: …c.ymcdn.com/sites/casss.site-ym.com/resource/resmgr/CE_Pharm...manufacturing process, ... From ASEAN Guideline on Analytical

17

18

19

20

21

22

23

24

25

26

27

1 4 7 10 13 16 19 22 25 28 31 34 37 40 43

15

17

19

21

23

25

27

29

31

33

35

1 4 7 10

13

16

19

22

25

28

31

34

37

40

43

Production Data Laboratory Controls

Where Lies The Problem Limits are set as per the usual practice plusmn 3 sigma

Understanding the data

18

19

20

21

22

23

24

25

26

0 5 10 15 20 25 30 35 40 45 50

1-P

oint

Ave

rage

0

05

1

15

2

25

3

35

4

45

5

Ran

ge

20

22

24

26

28

30

32

34

0 5 10 15 20 25 30 35 40 45 50

1-P

oint

Ave

rage

0

2

4

6

8

10

12

Ran

ge

Understanding the data

Shewhart Control Charts are Usedhellip

Global Emerging Markets

For most life cycle management activites focus on the

ldquoreferencerdquo markets eg US EMA Canada Japan

There are of course hundreds of other markets

The prominent and fast growing are referred to as Global

Emerging Markets

These markets are becoming strategically important for

the pharmaceutical industry

Global Emerging Markets

Country IMFNext-

11BRICCIVETS FTSE MSCI

THE

ECONOMI

ST

SampPDOW

JONESBBVA

Columbia

University

EMGP

Argentina

Bahrain

Bangladesh

Brazil

Chile

China

Colombia

Egypt

Hong Kong

India

Indonesia

Israel

Jordan

Kuwait

Malaysia

Mauritius

Mexico

Morocco

Nigeria

Global Emerging Markets

Country IMFNext-

11BRICCIVETS FTSE MSCI

THE

ECONOMI

ST

SampPDOW

JONESBBVA

Columbia

University

EMGP

Oman

Pakistan

Peru

Philippines

Qatar

Russia

Saudi Arabia

Singapore

South Africa

South Korea

Sri Lanka

Taiwan

Thailand

Tunisia

Turkey

UAE

Ukraine

Venezuela

Vietnam

Characteristics of GEM Regulatory Agencies

Many markets expect a major market (eg US or EMA)

approval before filing

- This facilitates approval in these countries

- Notable exceptions South Africa Brazil

Requirements and expertise can vary widely but both

are increasing

- Example Azerbaijan vs Russia vs India

- Example HSA (Singapore)

GEM Challenges

Regulations are evolving

- Advances ICH Pharmaceutical Inspection Coop Scheme

Regulations and guidelines (along with unstated

expectations) are not globally harmonized - Many country or region-specific requirements and interpretation of

guidance

- Pharmacopeia standards differ country to country

- GMPs are not globally harmonized

- Inspections are not globally harmonized

- Differences exist for reviewapproval times clinical trial application

content specification

- Approval of changes is not harmonized

- Post approval reporting requirements are not harmonized

18

GEM Challenges

Increasing complexity with foreign countries

bull Language time zones culture FMAs in-country testing

availability of instrumentation technical savvy

New requirements for some GEM countries

IP issues

Inspections

Multiple approved dossier versions for a single drug

- Multiple specifications multiple item codes different CoAs

different responses to questions

Overall Global CTD not possible

Understanding both the intent and expectations of

questions

19

In-country testing

Many countries require in country testing either before

approval or after launch of the product

Capillary electrophoresis (among other methodologies)

can be a challenge for some markets

Methods need to be robust () to facilitate transfer to

these markets

In-country testing (example)

Country Mandatory Requirement

Small Molecules Biologicals

Full vs Partial testing Local vs Contract Lab

Argentina Yes Yes Full Local Lab mandated

Brazil Yes NA Full Local Lab mandated

Chile Yes Yes Partial is possible Can be contracted out

Uruguay Yes Yes Theoretically full testing selected possible Can be contracted out

Mexico Yes Yes Full Testing (for n=20 batches) Then request a

reduction If tests are too expensive or require

sophisticated equipment reduction is possible

Testing is exempted for orphan drugs

Can be contracted out

Russia Yes Yes Full testing for new registrations Laboratory assigned by

MoH

Turkey Yes Yes Tests performed are based on the product but

normally these include Biological Dissolution

Physical physicochemical controls Content

uniformity amount Microbiological purity and ID

Official analysis institution

of TMOH

Ukraine Yes Yes Full testing State local laboratory

assigned by the MoH

Israel Yes Yes Full testing for the first imported batch and then

upon MoH request

Testing carried out by

MOH Lab

Other countries requiring testing Costa Rica DR El Salvador Ecuador Guatemala Honduras

Nicaragua Panama South Korea etc

GEM Requirements (examples) Brazil (Resolution RDC No 17 16 Apr 2010)

Article 19 Qualification and validation should not be considered only

exercises After the adoption of the qualification andor validation

report it there should have a continuous monitoring program which

must be based on periodic review [Note software validation and re-

validation is called out as a specific self-inspection item]

Article 209 Sole Paragraph Compendial analytical methods do not

require validation but before its implementation there must be

documented evidence of their suitability in the laboratory operating

conditions

Article 312 sect 3 The pharmacopoeial methods should be used for the

validation and performance of the sterility test

Article 463 sect 2 The retrospective validation is no longer encouraged

and is not applicable to the manufacture of sterile products

Article 479 sect 2 A risk assessment should be used to determine the

scope and extent of validation 22

GEM Requirements (examples) Thailand (QampA on ASEAN Analytical Validation)

6 Identify the conditionsscenarios when each of the following is

required to be conducted Full validation Revalidation Verification

Refer to 1 for Full validation and Verification According to ASEAN

Guideline revalidation may be required in the following circumstances

- Change in the synthesis of the drug substance

- Change in the composition of the finished product

- Change in the analytical procedure

From ASEAN Guideline on Analytical Validation (consistent with ICH)

The compendial methods are not required to be validated but merely

verify their suitability under actual conditions of use

23

GEM Requirements (examples) ASEAN Variation Guideline for Pharmaceutical

Products

Major Variation

- No analytical examples (not counting specification changes)

Minor Variation - Prior Approval (MiV-PA)

- Change of test procedure to non-compendial drug substance (must at

least show equivalence to former procedure) ndash MiV-PA9

- Change of in-process controls applied during the manufacture of the drug

substance (including tightening and addition of new in-process test) ndash MiV-

PA6

- Change of in-process controls applied during the manufacture of the drug

product (including tightening and addition of new in-process test) ndash MiV-

PA19

bull Interesting note Any new test method does not concern a novel non-standard

technique or a standard technique used in a novel way

Minor Variation - Notification (MiV-N)

- No analytical examples

24

GEM Requirements (examples) South Africa (Amendments)

Four categories

- Type A - amendments that may be implemented without intervention of or prior

notification to Council

- Type B - amendments that require prior notification

- Type C - amendments that require prior approval

- Type D - amendments that should be considered new applications

Type A Biological examples

- (25) Addition of release tests and or of specifications or tightening of

specifications for intermediates of the APIs

Type B Biological examples

- No analytical examples

25

GEM Requirements (examples) South Africa (Amendments)

Type C Biological examples

- (19B) Any change in analytical methods that

bull results in change(s) of specification limits or modification(s) in potency

sensitivity specificity or purity

bull establishes a new analytical method

bull deletes a specification or an analytical method

bull eliminates tests from the stability protocol or

bull alters the acceptance criteria of the stability protocol

- (20B) Any change in production processes that may

bull result in change(s) of specification limits or modification(s) in potency

sensitivity specificity or purity

bull establish a new analytical method

bull delete a specification or an analytical method

bull eliminate tests from the stability protocol or

bull alter the acceptance criteria of the stability protocol

26

Analytical Validation and Method Detail

(several)

Question Asked a series of questions on method details

requested method validation data for all methods used in

the analytical control strategy

Answer

- Provided copies of the methods and answered the specific

detail questions requested

- Some requests have included providing raw data (eg real

weight of reference standard and sample used) from validation

- This detail is requested as a substitute for in-country testing

thus preventing the need for in-country (repeat) testing

- The procedures are not considered ldquopart of the licenserdquo

Result Success

Method detail (South Korea)

Question Detailed test methods for API

Answer

- Provided descriptions of the assays but not copies of the methods

- These are not considered ldquopart of the licenserdquo (eg The detailed test

methods for Drug Substance are supplied as a reference The

information provided in Module 3 Section 32S42 Analytical

Procedures is considered to contain the regulatory information and

requirements)

Result Success

Detailed data (several)

Question Provide chromatograms and electropherograms for all

stability timepoints

Answer

- Provided chromatogramselectropherograms sometimes providing only

one lot instead of three lots

Result Success

Conclusions

Understanding analytical methods including real time

assessments of variability are becoming increasingly

important

The trends toward increased globalization will create

additional work and challenge for analytical professionals

Global Emerging Markets will become a larger portion of

the work due to increasing complexity in these markets

Acknowledgements

Catherine Anderson

Helena Madden

Sue Stella

Guidance list (non-inclusive) Region Topic ASEAN ASEAN GUIDELINE ON SUBMISSION OF MANUFACTURING PROCESS VALIDATION DATA FOR DRUG REGISTRATION

httpwwwhsagovsgpublishetcmedialibhsa_libraryhealth_products_regulationwestern_medicinesfiles_guidelinesPar96657FiledatA

SEAN20PV20(Version2031)20Main20Guide20without20annexespdf ASEAN VARIATION GUIDELINE FOR PHARMACEUTICAL PRODUCTS

httpwwwfdagovphattachmentsarticle95567ASEAN20Variation20Guideline20for20Pharmaceutical20Products20Final20

Draft207220(2013)pdf Thailand QampA on ASEAN Analytical Validation

httpwwwhsagovsgpublishetcmedialibhsa_libraryhealth_products_regulationwestern_medicinesfiles_guidelinesPar98887FiledatQ

ampA20analytical20validation-25jun55pdf ASEAN website with links to several guidances

httpwwwaseanorgcommunitiesasean-economic-communityitemharmonization-of-standards-and-technical-requirements-in-asean Brazil Resolution RDC No 27

httpwwwemergogroupcomfilesbrazil-resolution-rdc-no-27-21-june-2011pdf

Establishes Minimum Requirements for the Validation of Bioanalytical Methods Used in Pre- and Post-Marketing Studies

The validation of the analytical methods (Resolution RE 899 (IDRAC 39212) of 29-May-20033 and Resolution RDC 27 (IDRAC 143541) of

17-May-2012) is mandatory whenever the method is an in-house method or it is not described in pharmacopeias accepted by ANVISA Resolution RDC No 17

httpwwwabiquifiorgbrlegislacaoanvisaingles_rdc17pdf

16-Apr-2010 presents detailed guidelines about the validation and qualification requirements in the pharmaceutical industry as part of the

Good Manufacturing Practices Regulation Australia Note for Guidance on Validation of Analytical Procedures Text and Methodology

CPMPICH38195 (pdf183kb)

Japan Excerpt from presentation Japan has no guidance for bioanalytical method validation The answers in these slides are the results of the

discussion in the JBF kickoff meeting on March 30 (2011)1048579

httpwwwnihsgojpdrugBMVMontreal20110414_katoripdf Malaysia httpportalbpfkgovmyaeimagesFileAnalytical_Validation_Documents_of_Injections_Submission_Guidelinespdf Singapore ANALYTICAL METHOD VALIDATION

httpwwwhsagovsgpublishetcmedialibhsa_libraryhealth_products_regulationgmpfiles_1Par23186FiledatGUIDE-MQA-012A-

004pdf

Page 13: Capillary Electrophoresis in Global Emerging Markets: …c.ymcdn.com/sites/casss.site-ym.com/resource/resmgr/CE_Pharm...manufacturing process, ... From ASEAN Guideline on Analytical

18

19

20

21

22

23

24

25

26

0 5 10 15 20 25 30 35 40 45 50

1-P

oint

Ave

rage

0

05

1

15

2

25

3

35

4

45

5

Ran

ge

20

22

24

26

28

30

32

34

0 5 10 15 20 25 30 35 40 45 50

1-P

oint

Ave

rage

0

2

4

6

8

10

12

Ran

ge

Understanding the data

Shewhart Control Charts are Usedhellip

Global Emerging Markets

For most life cycle management activites focus on the

ldquoreferencerdquo markets eg US EMA Canada Japan

There are of course hundreds of other markets

The prominent and fast growing are referred to as Global

Emerging Markets

These markets are becoming strategically important for

the pharmaceutical industry

Global Emerging Markets

Country IMFNext-

11BRICCIVETS FTSE MSCI

THE

ECONOMI

ST

SampPDOW

JONESBBVA

Columbia

University

EMGP

Argentina

Bahrain

Bangladesh

Brazil

Chile

China

Colombia

Egypt

Hong Kong

India

Indonesia

Israel

Jordan

Kuwait

Malaysia

Mauritius

Mexico

Morocco

Nigeria

Global Emerging Markets

Country IMFNext-

11BRICCIVETS FTSE MSCI

THE

ECONOMI

ST

SampPDOW

JONESBBVA

Columbia

University

EMGP

Oman

Pakistan

Peru

Philippines

Qatar

Russia

Saudi Arabia

Singapore

South Africa

South Korea

Sri Lanka

Taiwan

Thailand

Tunisia

Turkey

UAE

Ukraine

Venezuela

Vietnam

Characteristics of GEM Regulatory Agencies

Many markets expect a major market (eg US or EMA)

approval before filing

- This facilitates approval in these countries

- Notable exceptions South Africa Brazil

Requirements and expertise can vary widely but both

are increasing

- Example Azerbaijan vs Russia vs India

- Example HSA (Singapore)

GEM Challenges

Regulations are evolving

- Advances ICH Pharmaceutical Inspection Coop Scheme

Regulations and guidelines (along with unstated

expectations) are not globally harmonized - Many country or region-specific requirements and interpretation of

guidance

- Pharmacopeia standards differ country to country

- GMPs are not globally harmonized

- Inspections are not globally harmonized

- Differences exist for reviewapproval times clinical trial application

content specification

- Approval of changes is not harmonized

- Post approval reporting requirements are not harmonized

18

GEM Challenges

Increasing complexity with foreign countries

bull Language time zones culture FMAs in-country testing

availability of instrumentation technical savvy

New requirements for some GEM countries

IP issues

Inspections

Multiple approved dossier versions for a single drug

- Multiple specifications multiple item codes different CoAs

different responses to questions

Overall Global CTD not possible

Understanding both the intent and expectations of

questions

19

In-country testing

Many countries require in country testing either before

approval or after launch of the product

Capillary electrophoresis (among other methodologies)

can be a challenge for some markets

Methods need to be robust () to facilitate transfer to

these markets

In-country testing (example)

Country Mandatory Requirement

Small Molecules Biologicals

Full vs Partial testing Local vs Contract Lab

Argentina Yes Yes Full Local Lab mandated

Brazil Yes NA Full Local Lab mandated

Chile Yes Yes Partial is possible Can be contracted out

Uruguay Yes Yes Theoretically full testing selected possible Can be contracted out

Mexico Yes Yes Full Testing (for n=20 batches) Then request a

reduction If tests are too expensive or require

sophisticated equipment reduction is possible

Testing is exempted for orphan drugs

Can be contracted out

Russia Yes Yes Full testing for new registrations Laboratory assigned by

MoH

Turkey Yes Yes Tests performed are based on the product but

normally these include Biological Dissolution

Physical physicochemical controls Content

uniformity amount Microbiological purity and ID

Official analysis institution

of TMOH

Ukraine Yes Yes Full testing State local laboratory

assigned by the MoH

Israel Yes Yes Full testing for the first imported batch and then

upon MoH request

Testing carried out by

MOH Lab

Other countries requiring testing Costa Rica DR El Salvador Ecuador Guatemala Honduras

Nicaragua Panama South Korea etc

GEM Requirements (examples) Brazil (Resolution RDC No 17 16 Apr 2010)

Article 19 Qualification and validation should not be considered only

exercises After the adoption of the qualification andor validation

report it there should have a continuous monitoring program which

must be based on periodic review [Note software validation and re-

validation is called out as a specific self-inspection item]

Article 209 Sole Paragraph Compendial analytical methods do not

require validation but before its implementation there must be

documented evidence of their suitability in the laboratory operating

conditions

Article 312 sect 3 The pharmacopoeial methods should be used for the

validation and performance of the sterility test

Article 463 sect 2 The retrospective validation is no longer encouraged

and is not applicable to the manufacture of sterile products

Article 479 sect 2 A risk assessment should be used to determine the

scope and extent of validation 22

GEM Requirements (examples) Thailand (QampA on ASEAN Analytical Validation)

6 Identify the conditionsscenarios when each of the following is

required to be conducted Full validation Revalidation Verification

Refer to 1 for Full validation and Verification According to ASEAN

Guideline revalidation may be required in the following circumstances

- Change in the synthesis of the drug substance

- Change in the composition of the finished product

- Change in the analytical procedure

From ASEAN Guideline on Analytical Validation (consistent with ICH)

The compendial methods are not required to be validated but merely

verify their suitability under actual conditions of use

23

GEM Requirements (examples) ASEAN Variation Guideline for Pharmaceutical

Products

Major Variation

- No analytical examples (not counting specification changes)

Minor Variation - Prior Approval (MiV-PA)

- Change of test procedure to non-compendial drug substance (must at

least show equivalence to former procedure) ndash MiV-PA9

- Change of in-process controls applied during the manufacture of the drug

substance (including tightening and addition of new in-process test) ndash MiV-

PA6

- Change of in-process controls applied during the manufacture of the drug

product (including tightening and addition of new in-process test) ndash MiV-

PA19

bull Interesting note Any new test method does not concern a novel non-standard

technique or a standard technique used in a novel way

Minor Variation - Notification (MiV-N)

- No analytical examples

24

GEM Requirements (examples) South Africa (Amendments)

Four categories

- Type A - amendments that may be implemented without intervention of or prior

notification to Council

- Type B - amendments that require prior notification

- Type C - amendments that require prior approval

- Type D - amendments that should be considered new applications

Type A Biological examples

- (25) Addition of release tests and or of specifications or tightening of

specifications for intermediates of the APIs

Type B Biological examples

- No analytical examples

25

GEM Requirements (examples) South Africa (Amendments)

Type C Biological examples

- (19B) Any change in analytical methods that

bull results in change(s) of specification limits or modification(s) in potency

sensitivity specificity or purity

bull establishes a new analytical method

bull deletes a specification or an analytical method

bull eliminates tests from the stability protocol or

bull alters the acceptance criteria of the stability protocol

- (20B) Any change in production processes that may

bull result in change(s) of specification limits or modification(s) in potency

sensitivity specificity or purity

bull establish a new analytical method

bull delete a specification or an analytical method

bull eliminate tests from the stability protocol or

bull alter the acceptance criteria of the stability protocol

26

Analytical Validation and Method Detail

(several)

Question Asked a series of questions on method details

requested method validation data for all methods used in

the analytical control strategy

Answer

- Provided copies of the methods and answered the specific

detail questions requested

- Some requests have included providing raw data (eg real

weight of reference standard and sample used) from validation

- This detail is requested as a substitute for in-country testing

thus preventing the need for in-country (repeat) testing

- The procedures are not considered ldquopart of the licenserdquo

Result Success

Method detail (South Korea)

Question Detailed test methods for API

Answer

- Provided descriptions of the assays but not copies of the methods

- These are not considered ldquopart of the licenserdquo (eg The detailed test

methods for Drug Substance are supplied as a reference The

information provided in Module 3 Section 32S42 Analytical

Procedures is considered to contain the regulatory information and

requirements)

Result Success

Detailed data (several)

Question Provide chromatograms and electropherograms for all

stability timepoints

Answer

- Provided chromatogramselectropherograms sometimes providing only

one lot instead of three lots

Result Success

Conclusions

Understanding analytical methods including real time

assessments of variability are becoming increasingly

important

The trends toward increased globalization will create

additional work and challenge for analytical professionals

Global Emerging Markets will become a larger portion of

the work due to increasing complexity in these markets

Acknowledgements

Catherine Anderson

Helena Madden

Sue Stella

Guidance list (non-inclusive) Region Topic ASEAN ASEAN GUIDELINE ON SUBMISSION OF MANUFACTURING PROCESS VALIDATION DATA FOR DRUG REGISTRATION

httpwwwhsagovsgpublishetcmedialibhsa_libraryhealth_products_regulationwestern_medicinesfiles_guidelinesPar96657FiledatA

SEAN20PV20(Version2031)20Main20Guide20without20annexespdf ASEAN VARIATION GUIDELINE FOR PHARMACEUTICAL PRODUCTS

httpwwwfdagovphattachmentsarticle95567ASEAN20Variation20Guideline20for20Pharmaceutical20Products20Final20

Draft207220(2013)pdf Thailand QampA on ASEAN Analytical Validation

httpwwwhsagovsgpublishetcmedialibhsa_libraryhealth_products_regulationwestern_medicinesfiles_guidelinesPar98887FiledatQ

ampA20analytical20validation-25jun55pdf ASEAN website with links to several guidances

httpwwwaseanorgcommunitiesasean-economic-communityitemharmonization-of-standards-and-technical-requirements-in-asean Brazil Resolution RDC No 27

httpwwwemergogroupcomfilesbrazil-resolution-rdc-no-27-21-june-2011pdf

Establishes Minimum Requirements for the Validation of Bioanalytical Methods Used in Pre- and Post-Marketing Studies

The validation of the analytical methods (Resolution RE 899 (IDRAC 39212) of 29-May-20033 and Resolution RDC 27 (IDRAC 143541) of

17-May-2012) is mandatory whenever the method is an in-house method or it is not described in pharmacopeias accepted by ANVISA Resolution RDC No 17

httpwwwabiquifiorgbrlegislacaoanvisaingles_rdc17pdf

16-Apr-2010 presents detailed guidelines about the validation and qualification requirements in the pharmaceutical industry as part of the

Good Manufacturing Practices Regulation Australia Note for Guidance on Validation of Analytical Procedures Text and Methodology

CPMPICH38195 (pdf183kb)

Japan Excerpt from presentation Japan has no guidance for bioanalytical method validation The answers in these slides are the results of the

discussion in the JBF kickoff meeting on March 30 (2011)1048579

httpwwwnihsgojpdrugBMVMontreal20110414_katoripdf Malaysia httpportalbpfkgovmyaeimagesFileAnalytical_Validation_Documents_of_Injections_Submission_Guidelinespdf Singapore ANALYTICAL METHOD VALIDATION

httpwwwhsagovsgpublishetcmedialibhsa_libraryhealth_products_regulationgmpfiles_1Par23186FiledatGUIDE-MQA-012A-

004pdf

Page 14: Capillary Electrophoresis in Global Emerging Markets: …c.ymcdn.com/sites/casss.site-ym.com/resource/resmgr/CE_Pharm...manufacturing process, ... From ASEAN Guideline on Analytical

Global Emerging Markets

For most life cycle management activites focus on the

ldquoreferencerdquo markets eg US EMA Canada Japan

There are of course hundreds of other markets

The prominent and fast growing are referred to as Global

Emerging Markets

These markets are becoming strategically important for

the pharmaceutical industry

Global Emerging Markets

Country IMFNext-

11BRICCIVETS FTSE MSCI

THE

ECONOMI

ST

SampPDOW

JONESBBVA

Columbia

University

EMGP

Argentina

Bahrain

Bangladesh

Brazil

Chile

China

Colombia

Egypt

Hong Kong

India

Indonesia

Israel

Jordan

Kuwait

Malaysia

Mauritius

Mexico

Morocco

Nigeria

Global Emerging Markets

Country IMFNext-

11BRICCIVETS FTSE MSCI

THE

ECONOMI

ST

SampPDOW

JONESBBVA

Columbia

University

EMGP

Oman

Pakistan

Peru

Philippines

Qatar

Russia

Saudi Arabia

Singapore

South Africa

South Korea

Sri Lanka

Taiwan

Thailand

Tunisia

Turkey

UAE

Ukraine

Venezuela

Vietnam

Characteristics of GEM Regulatory Agencies

Many markets expect a major market (eg US or EMA)

approval before filing

- This facilitates approval in these countries

- Notable exceptions South Africa Brazil

Requirements and expertise can vary widely but both

are increasing

- Example Azerbaijan vs Russia vs India

- Example HSA (Singapore)

GEM Challenges

Regulations are evolving

- Advances ICH Pharmaceutical Inspection Coop Scheme

Regulations and guidelines (along with unstated

expectations) are not globally harmonized - Many country or region-specific requirements and interpretation of

guidance

- Pharmacopeia standards differ country to country

- GMPs are not globally harmonized

- Inspections are not globally harmonized

- Differences exist for reviewapproval times clinical trial application

content specification

- Approval of changes is not harmonized

- Post approval reporting requirements are not harmonized

18

GEM Challenges

Increasing complexity with foreign countries

bull Language time zones culture FMAs in-country testing

availability of instrumentation technical savvy

New requirements for some GEM countries

IP issues

Inspections

Multiple approved dossier versions for a single drug

- Multiple specifications multiple item codes different CoAs

different responses to questions

Overall Global CTD not possible

Understanding both the intent and expectations of

questions

19

In-country testing

Many countries require in country testing either before

approval or after launch of the product

Capillary electrophoresis (among other methodologies)

can be a challenge for some markets

Methods need to be robust () to facilitate transfer to

these markets

In-country testing (example)

Country Mandatory Requirement

Small Molecules Biologicals

Full vs Partial testing Local vs Contract Lab

Argentina Yes Yes Full Local Lab mandated

Brazil Yes NA Full Local Lab mandated

Chile Yes Yes Partial is possible Can be contracted out

Uruguay Yes Yes Theoretically full testing selected possible Can be contracted out

Mexico Yes Yes Full Testing (for n=20 batches) Then request a

reduction If tests are too expensive or require

sophisticated equipment reduction is possible

Testing is exempted for orphan drugs

Can be contracted out

Russia Yes Yes Full testing for new registrations Laboratory assigned by

MoH

Turkey Yes Yes Tests performed are based on the product but

normally these include Biological Dissolution

Physical physicochemical controls Content

uniformity amount Microbiological purity and ID

Official analysis institution

of TMOH

Ukraine Yes Yes Full testing State local laboratory

assigned by the MoH

Israel Yes Yes Full testing for the first imported batch and then

upon MoH request

Testing carried out by

MOH Lab

Other countries requiring testing Costa Rica DR El Salvador Ecuador Guatemala Honduras

Nicaragua Panama South Korea etc

GEM Requirements (examples) Brazil (Resolution RDC No 17 16 Apr 2010)

Article 19 Qualification and validation should not be considered only

exercises After the adoption of the qualification andor validation

report it there should have a continuous monitoring program which

must be based on periodic review [Note software validation and re-

validation is called out as a specific self-inspection item]

Article 209 Sole Paragraph Compendial analytical methods do not

require validation but before its implementation there must be

documented evidence of their suitability in the laboratory operating

conditions

Article 312 sect 3 The pharmacopoeial methods should be used for the

validation and performance of the sterility test

Article 463 sect 2 The retrospective validation is no longer encouraged

and is not applicable to the manufacture of sterile products

Article 479 sect 2 A risk assessment should be used to determine the

scope and extent of validation 22

GEM Requirements (examples) Thailand (QampA on ASEAN Analytical Validation)

6 Identify the conditionsscenarios when each of the following is

required to be conducted Full validation Revalidation Verification

Refer to 1 for Full validation and Verification According to ASEAN

Guideline revalidation may be required in the following circumstances

- Change in the synthesis of the drug substance

- Change in the composition of the finished product

- Change in the analytical procedure

From ASEAN Guideline on Analytical Validation (consistent with ICH)

The compendial methods are not required to be validated but merely

verify their suitability under actual conditions of use

23

GEM Requirements (examples) ASEAN Variation Guideline for Pharmaceutical

Products

Major Variation

- No analytical examples (not counting specification changes)

Minor Variation - Prior Approval (MiV-PA)

- Change of test procedure to non-compendial drug substance (must at

least show equivalence to former procedure) ndash MiV-PA9

- Change of in-process controls applied during the manufacture of the drug

substance (including tightening and addition of new in-process test) ndash MiV-

PA6

- Change of in-process controls applied during the manufacture of the drug

product (including tightening and addition of new in-process test) ndash MiV-

PA19

bull Interesting note Any new test method does not concern a novel non-standard

technique or a standard technique used in a novel way

Minor Variation - Notification (MiV-N)

- No analytical examples

24

GEM Requirements (examples) South Africa (Amendments)

Four categories

- Type A - amendments that may be implemented without intervention of or prior

notification to Council

- Type B - amendments that require prior notification

- Type C - amendments that require prior approval

- Type D - amendments that should be considered new applications

Type A Biological examples

- (25) Addition of release tests and or of specifications or tightening of

specifications for intermediates of the APIs

Type B Biological examples

- No analytical examples

25

GEM Requirements (examples) South Africa (Amendments)

Type C Biological examples

- (19B) Any change in analytical methods that

bull results in change(s) of specification limits or modification(s) in potency

sensitivity specificity or purity

bull establishes a new analytical method

bull deletes a specification or an analytical method

bull eliminates tests from the stability protocol or

bull alters the acceptance criteria of the stability protocol

- (20B) Any change in production processes that may

bull result in change(s) of specification limits or modification(s) in potency

sensitivity specificity or purity

bull establish a new analytical method

bull delete a specification or an analytical method

bull eliminate tests from the stability protocol or

bull alter the acceptance criteria of the stability protocol

26

Analytical Validation and Method Detail

(several)

Question Asked a series of questions on method details

requested method validation data for all methods used in

the analytical control strategy

Answer

- Provided copies of the methods and answered the specific

detail questions requested

- Some requests have included providing raw data (eg real

weight of reference standard and sample used) from validation

- This detail is requested as a substitute for in-country testing

thus preventing the need for in-country (repeat) testing

- The procedures are not considered ldquopart of the licenserdquo

Result Success

Method detail (South Korea)

Question Detailed test methods for API

Answer

- Provided descriptions of the assays but not copies of the methods

- These are not considered ldquopart of the licenserdquo (eg The detailed test

methods for Drug Substance are supplied as a reference The

information provided in Module 3 Section 32S42 Analytical

Procedures is considered to contain the regulatory information and

requirements)

Result Success

Detailed data (several)

Question Provide chromatograms and electropherograms for all

stability timepoints

Answer

- Provided chromatogramselectropherograms sometimes providing only

one lot instead of three lots

Result Success

Conclusions

Understanding analytical methods including real time

assessments of variability are becoming increasingly

important

The trends toward increased globalization will create

additional work and challenge for analytical professionals

Global Emerging Markets will become a larger portion of

the work due to increasing complexity in these markets

Acknowledgements

Catherine Anderson

Helena Madden

Sue Stella

Guidance list (non-inclusive) Region Topic ASEAN ASEAN GUIDELINE ON SUBMISSION OF MANUFACTURING PROCESS VALIDATION DATA FOR DRUG REGISTRATION

httpwwwhsagovsgpublishetcmedialibhsa_libraryhealth_products_regulationwestern_medicinesfiles_guidelinesPar96657FiledatA

SEAN20PV20(Version2031)20Main20Guide20without20annexespdf ASEAN VARIATION GUIDELINE FOR PHARMACEUTICAL PRODUCTS

httpwwwfdagovphattachmentsarticle95567ASEAN20Variation20Guideline20for20Pharmaceutical20Products20Final20

Draft207220(2013)pdf Thailand QampA on ASEAN Analytical Validation

httpwwwhsagovsgpublishetcmedialibhsa_libraryhealth_products_regulationwestern_medicinesfiles_guidelinesPar98887FiledatQ

ampA20analytical20validation-25jun55pdf ASEAN website with links to several guidances

httpwwwaseanorgcommunitiesasean-economic-communityitemharmonization-of-standards-and-technical-requirements-in-asean Brazil Resolution RDC No 27

httpwwwemergogroupcomfilesbrazil-resolution-rdc-no-27-21-june-2011pdf

Establishes Minimum Requirements for the Validation of Bioanalytical Methods Used in Pre- and Post-Marketing Studies

The validation of the analytical methods (Resolution RE 899 (IDRAC 39212) of 29-May-20033 and Resolution RDC 27 (IDRAC 143541) of

17-May-2012) is mandatory whenever the method is an in-house method or it is not described in pharmacopeias accepted by ANVISA Resolution RDC No 17

httpwwwabiquifiorgbrlegislacaoanvisaingles_rdc17pdf

16-Apr-2010 presents detailed guidelines about the validation and qualification requirements in the pharmaceutical industry as part of the

Good Manufacturing Practices Regulation Australia Note for Guidance on Validation of Analytical Procedures Text and Methodology

CPMPICH38195 (pdf183kb)

Japan Excerpt from presentation Japan has no guidance for bioanalytical method validation The answers in these slides are the results of the

discussion in the JBF kickoff meeting on March 30 (2011)1048579

httpwwwnihsgojpdrugBMVMontreal20110414_katoripdf Malaysia httpportalbpfkgovmyaeimagesFileAnalytical_Validation_Documents_of_Injections_Submission_Guidelinespdf Singapore ANALYTICAL METHOD VALIDATION

httpwwwhsagovsgpublishetcmedialibhsa_libraryhealth_products_regulationgmpfiles_1Par23186FiledatGUIDE-MQA-012A-

004pdf

Page 15: Capillary Electrophoresis in Global Emerging Markets: …c.ymcdn.com/sites/casss.site-ym.com/resource/resmgr/CE_Pharm...manufacturing process, ... From ASEAN Guideline on Analytical

Global Emerging Markets

Country IMFNext-

11BRICCIVETS FTSE MSCI

THE

ECONOMI

ST

SampPDOW

JONESBBVA

Columbia

University

EMGP

Argentina

Bahrain

Bangladesh

Brazil

Chile

China

Colombia

Egypt

Hong Kong

India

Indonesia

Israel

Jordan

Kuwait

Malaysia

Mauritius

Mexico

Morocco

Nigeria

Global Emerging Markets

Country IMFNext-

11BRICCIVETS FTSE MSCI

THE

ECONOMI

ST

SampPDOW

JONESBBVA

Columbia

University

EMGP

Oman

Pakistan

Peru

Philippines

Qatar

Russia

Saudi Arabia

Singapore

South Africa

South Korea

Sri Lanka

Taiwan

Thailand

Tunisia

Turkey

UAE

Ukraine

Venezuela

Vietnam

Characteristics of GEM Regulatory Agencies

Many markets expect a major market (eg US or EMA)

approval before filing

- This facilitates approval in these countries

- Notable exceptions South Africa Brazil

Requirements and expertise can vary widely but both

are increasing

- Example Azerbaijan vs Russia vs India

- Example HSA (Singapore)

GEM Challenges

Regulations are evolving

- Advances ICH Pharmaceutical Inspection Coop Scheme

Regulations and guidelines (along with unstated

expectations) are not globally harmonized - Many country or region-specific requirements and interpretation of

guidance

- Pharmacopeia standards differ country to country

- GMPs are not globally harmonized

- Inspections are not globally harmonized

- Differences exist for reviewapproval times clinical trial application

content specification

- Approval of changes is not harmonized

- Post approval reporting requirements are not harmonized

18

GEM Challenges

Increasing complexity with foreign countries

bull Language time zones culture FMAs in-country testing

availability of instrumentation technical savvy

New requirements for some GEM countries

IP issues

Inspections

Multiple approved dossier versions for a single drug

- Multiple specifications multiple item codes different CoAs

different responses to questions

Overall Global CTD not possible

Understanding both the intent and expectations of

questions

19

In-country testing

Many countries require in country testing either before

approval or after launch of the product

Capillary electrophoresis (among other methodologies)

can be a challenge for some markets

Methods need to be robust () to facilitate transfer to

these markets

In-country testing (example)

Country Mandatory Requirement

Small Molecules Biologicals

Full vs Partial testing Local vs Contract Lab

Argentina Yes Yes Full Local Lab mandated

Brazil Yes NA Full Local Lab mandated

Chile Yes Yes Partial is possible Can be contracted out

Uruguay Yes Yes Theoretically full testing selected possible Can be contracted out

Mexico Yes Yes Full Testing (for n=20 batches) Then request a

reduction If tests are too expensive or require

sophisticated equipment reduction is possible

Testing is exempted for orphan drugs

Can be contracted out

Russia Yes Yes Full testing for new registrations Laboratory assigned by

MoH

Turkey Yes Yes Tests performed are based on the product but

normally these include Biological Dissolution

Physical physicochemical controls Content

uniformity amount Microbiological purity and ID

Official analysis institution

of TMOH

Ukraine Yes Yes Full testing State local laboratory

assigned by the MoH

Israel Yes Yes Full testing for the first imported batch and then

upon MoH request

Testing carried out by

MOH Lab

Other countries requiring testing Costa Rica DR El Salvador Ecuador Guatemala Honduras

Nicaragua Panama South Korea etc

GEM Requirements (examples) Brazil (Resolution RDC No 17 16 Apr 2010)

Article 19 Qualification and validation should not be considered only

exercises After the adoption of the qualification andor validation

report it there should have a continuous monitoring program which

must be based on periodic review [Note software validation and re-

validation is called out as a specific self-inspection item]

Article 209 Sole Paragraph Compendial analytical methods do not

require validation but before its implementation there must be

documented evidence of their suitability in the laboratory operating

conditions

Article 312 sect 3 The pharmacopoeial methods should be used for the

validation and performance of the sterility test

Article 463 sect 2 The retrospective validation is no longer encouraged

and is not applicable to the manufacture of sterile products

Article 479 sect 2 A risk assessment should be used to determine the

scope and extent of validation 22

GEM Requirements (examples) Thailand (QampA on ASEAN Analytical Validation)

6 Identify the conditionsscenarios when each of the following is

required to be conducted Full validation Revalidation Verification

Refer to 1 for Full validation and Verification According to ASEAN

Guideline revalidation may be required in the following circumstances

- Change in the synthesis of the drug substance

- Change in the composition of the finished product

- Change in the analytical procedure

From ASEAN Guideline on Analytical Validation (consistent with ICH)

The compendial methods are not required to be validated but merely

verify their suitability under actual conditions of use

23

GEM Requirements (examples) ASEAN Variation Guideline for Pharmaceutical

Products

Major Variation

- No analytical examples (not counting specification changes)

Minor Variation - Prior Approval (MiV-PA)

- Change of test procedure to non-compendial drug substance (must at

least show equivalence to former procedure) ndash MiV-PA9

- Change of in-process controls applied during the manufacture of the drug

substance (including tightening and addition of new in-process test) ndash MiV-

PA6

- Change of in-process controls applied during the manufacture of the drug

product (including tightening and addition of new in-process test) ndash MiV-

PA19

bull Interesting note Any new test method does not concern a novel non-standard

technique or a standard technique used in a novel way

Minor Variation - Notification (MiV-N)

- No analytical examples

24

GEM Requirements (examples) South Africa (Amendments)

Four categories

- Type A - amendments that may be implemented without intervention of or prior

notification to Council

- Type B - amendments that require prior notification

- Type C - amendments that require prior approval

- Type D - amendments that should be considered new applications

Type A Biological examples

- (25) Addition of release tests and or of specifications or tightening of

specifications for intermediates of the APIs

Type B Biological examples

- No analytical examples

25

GEM Requirements (examples) South Africa (Amendments)

Type C Biological examples

- (19B) Any change in analytical methods that

bull results in change(s) of specification limits or modification(s) in potency

sensitivity specificity or purity

bull establishes a new analytical method

bull deletes a specification or an analytical method

bull eliminates tests from the stability protocol or

bull alters the acceptance criteria of the stability protocol

- (20B) Any change in production processes that may

bull result in change(s) of specification limits or modification(s) in potency

sensitivity specificity or purity

bull establish a new analytical method

bull delete a specification or an analytical method

bull eliminate tests from the stability protocol or

bull alter the acceptance criteria of the stability protocol

26

Analytical Validation and Method Detail

(several)

Question Asked a series of questions on method details

requested method validation data for all methods used in

the analytical control strategy

Answer

- Provided copies of the methods and answered the specific

detail questions requested

- Some requests have included providing raw data (eg real

weight of reference standard and sample used) from validation

- This detail is requested as a substitute for in-country testing

thus preventing the need for in-country (repeat) testing

- The procedures are not considered ldquopart of the licenserdquo

Result Success

Method detail (South Korea)

Question Detailed test methods for API

Answer

- Provided descriptions of the assays but not copies of the methods

- These are not considered ldquopart of the licenserdquo (eg The detailed test

methods for Drug Substance are supplied as a reference The

information provided in Module 3 Section 32S42 Analytical

Procedures is considered to contain the regulatory information and

requirements)

Result Success

Detailed data (several)

Question Provide chromatograms and electropherograms for all

stability timepoints

Answer

- Provided chromatogramselectropherograms sometimes providing only

one lot instead of three lots

Result Success

Conclusions

Understanding analytical methods including real time

assessments of variability are becoming increasingly

important

The trends toward increased globalization will create

additional work and challenge for analytical professionals

Global Emerging Markets will become a larger portion of

the work due to increasing complexity in these markets

Acknowledgements

Catherine Anderson

Helena Madden

Sue Stella

Guidance list (non-inclusive) Region Topic ASEAN ASEAN GUIDELINE ON SUBMISSION OF MANUFACTURING PROCESS VALIDATION DATA FOR DRUG REGISTRATION

httpwwwhsagovsgpublishetcmedialibhsa_libraryhealth_products_regulationwestern_medicinesfiles_guidelinesPar96657FiledatA

SEAN20PV20(Version2031)20Main20Guide20without20annexespdf ASEAN VARIATION GUIDELINE FOR PHARMACEUTICAL PRODUCTS

httpwwwfdagovphattachmentsarticle95567ASEAN20Variation20Guideline20for20Pharmaceutical20Products20Final20

Draft207220(2013)pdf Thailand QampA on ASEAN Analytical Validation

httpwwwhsagovsgpublishetcmedialibhsa_libraryhealth_products_regulationwestern_medicinesfiles_guidelinesPar98887FiledatQ

ampA20analytical20validation-25jun55pdf ASEAN website with links to several guidances

httpwwwaseanorgcommunitiesasean-economic-communityitemharmonization-of-standards-and-technical-requirements-in-asean Brazil Resolution RDC No 27

httpwwwemergogroupcomfilesbrazil-resolution-rdc-no-27-21-june-2011pdf

Establishes Minimum Requirements for the Validation of Bioanalytical Methods Used in Pre- and Post-Marketing Studies

The validation of the analytical methods (Resolution RE 899 (IDRAC 39212) of 29-May-20033 and Resolution RDC 27 (IDRAC 143541) of

17-May-2012) is mandatory whenever the method is an in-house method or it is not described in pharmacopeias accepted by ANVISA Resolution RDC No 17

httpwwwabiquifiorgbrlegislacaoanvisaingles_rdc17pdf

16-Apr-2010 presents detailed guidelines about the validation and qualification requirements in the pharmaceutical industry as part of the

Good Manufacturing Practices Regulation Australia Note for Guidance on Validation of Analytical Procedures Text and Methodology

CPMPICH38195 (pdf183kb)

Japan Excerpt from presentation Japan has no guidance for bioanalytical method validation The answers in these slides are the results of the

discussion in the JBF kickoff meeting on March 30 (2011)1048579

httpwwwnihsgojpdrugBMVMontreal20110414_katoripdf Malaysia httpportalbpfkgovmyaeimagesFileAnalytical_Validation_Documents_of_Injections_Submission_Guidelinespdf Singapore ANALYTICAL METHOD VALIDATION

httpwwwhsagovsgpublishetcmedialibhsa_libraryhealth_products_regulationgmpfiles_1Par23186FiledatGUIDE-MQA-012A-

004pdf

Page 16: Capillary Electrophoresis in Global Emerging Markets: …c.ymcdn.com/sites/casss.site-ym.com/resource/resmgr/CE_Pharm...manufacturing process, ... From ASEAN Guideline on Analytical

Global Emerging Markets

Country IMFNext-

11BRICCIVETS FTSE MSCI

THE

ECONOMI

ST

SampPDOW

JONESBBVA

Columbia

University

EMGP

Oman

Pakistan

Peru

Philippines

Qatar

Russia

Saudi Arabia

Singapore

South Africa

South Korea

Sri Lanka

Taiwan

Thailand

Tunisia

Turkey

UAE

Ukraine

Venezuela

Vietnam

Characteristics of GEM Regulatory Agencies

Many markets expect a major market (eg US or EMA)

approval before filing

- This facilitates approval in these countries

- Notable exceptions South Africa Brazil

Requirements and expertise can vary widely but both

are increasing

- Example Azerbaijan vs Russia vs India

- Example HSA (Singapore)

GEM Challenges

Regulations are evolving

- Advances ICH Pharmaceutical Inspection Coop Scheme

Regulations and guidelines (along with unstated

expectations) are not globally harmonized - Many country or region-specific requirements and interpretation of

guidance

- Pharmacopeia standards differ country to country

- GMPs are not globally harmonized

- Inspections are not globally harmonized

- Differences exist for reviewapproval times clinical trial application

content specification

- Approval of changes is not harmonized

- Post approval reporting requirements are not harmonized

18

GEM Challenges

Increasing complexity with foreign countries

bull Language time zones culture FMAs in-country testing

availability of instrumentation technical savvy

New requirements for some GEM countries

IP issues

Inspections

Multiple approved dossier versions for a single drug

- Multiple specifications multiple item codes different CoAs

different responses to questions

Overall Global CTD not possible

Understanding both the intent and expectations of

questions

19

In-country testing

Many countries require in country testing either before

approval or after launch of the product

Capillary electrophoresis (among other methodologies)

can be a challenge for some markets

Methods need to be robust () to facilitate transfer to

these markets

In-country testing (example)

Country Mandatory Requirement

Small Molecules Biologicals

Full vs Partial testing Local vs Contract Lab

Argentina Yes Yes Full Local Lab mandated

Brazil Yes NA Full Local Lab mandated

Chile Yes Yes Partial is possible Can be contracted out

Uruguay Yes Yes Theoretically full testing selected possible Can be contracted out

Mexico Yes Yes Full Testing (for n=20 batches) Then request a

reduction If tests are too expensive or require

sophisticated equipment reduction is possible

Testing is exempted for orphan drugs

Can be contracted out

Russia Yes Yes Full testing for new registrations Laboratory assigned by

MoH

Turkey Yes Yes Tests performed are based on the product but

normally these include Biological Dissolution

Physical physicochemical controls Content

uniformity amount Microbiological purity and ID

Official analysis institution

of TMOH

Ukraine Yes Yes Full testing State local laboratory

assigned by the MoH

Israel Yes Yes Full testing for the first imported batch and then

upon MoH request

Testing carried out by

MOH Lab

Other countries requiring testing Costa Rica DR El Salvador Ecuador Guatemala Honduras

Nicaragua Panama South Korea etc

GEM Requirements (examples) Brazil (Resolution RDC No 17 16 Apr 2010)

Article 19 Qualification and validation should not be considered only

exercises After the adoption of the qualification andor validation

report it there should have a continuous monitoring program which

must be based on periodic review [Note software validation and re-

validation is called out as a specific self-inspection item]

Article 209 Sole Paragraph Compendial analytical methods do not

require validation but before its implementation there must be

documented evidence of their suitability in the laboratory operating

conditions

Article 312 sect 3 The pharmacopoeial methods should be used for the

validation and performance of the sterility test

Article 463 sect 2 The retrospective validation is no longer encouraged

and is not applicable to the manufacture of sterile products

Article 479 sect 2 A risk assessment should be used to determine the

scope and extent of validation 22

GEM Requirements (examples) Thailand (QampA on ASEAN Analytical Validation)

6 Identify the conditionsscenarios when each of the following is

required to be conducted Full validation Revalidation Verification

Refer to 1 for Full validation and Verification According to ASEAN

Guideline revalidation may be required in the following circumstances

- Change in the synthesis of the drug substance

- Change in the composition of the finished product

- Change in the analytical procedure

From ASEAN Guideline on Analytical Validation (consistent with ICH)

The compendial methods are not required to be validated but merely

verify their suitability under actual conditions of use

23

GEM Requirements (examples) ASEAN Variation Guideline for Pharmaceutical

Products

Major Variation

- No analytical examples (not counting specification changes)

Minor Variation - Prior Approval (MiV-PA)

- Change of test procedure to non-compendial drug substance (must at

least show equivalence to former procedure) ndash MiV-PA9

- Change of in-process controls applied during the manufacture of the drug

substance (including tightening and addition of new in-process test) ndash MiV-

PA6

- Change of in-process controls applied during the manufacture of the drug

product (including tightening and addition of new in-process test) ndash MiV-

PA19

bull Interesting note Any new test method does not concern a novel non-standard

technique or a standard technique used in a novel way

Minor Variation - Notification (MiV-N)

- No analytical examples

24

GEM Requirements (examples) South Africa (Amendments)

Four categories

- Type A - amendments that may be implemented without intervention of or prior

notification to Council

- Type B - amendments that require prior notification

- Type C - amendments that require prior approval

- Type D - amendments that should be considered new applications

Type A Biological examples

- (25) Addition of release tests and or of specifications or tightening of

specifications for intermediates of the APIs

Type B Biological examples

- No analytical examples

25

GEM Requirements (examples) South Africa (Amendments)

Type C Biological examples

- (19B) Any change in analytical methods that

bull results in change(s) of specification limits or modification(s) in potency

sensitivity specificity or purity

bull establishes a new analytical method

bull deletes a specification or an analytical method

bull eliminates tests from the stability protocol or

bull alters the acceptance criteria of the stability protocol

- (20B) Any change in production processes that may

bull result in change(s) of specification limits or modification(s) in potency

sensitivity specificity or purity

bull establish a new analytical method

bull delete a specification or an analytical method

bull eliminate tests from the stability protocol or

bull alter the acceptance criteria of the stability protocol

26

Analytical Validation and Method Detail

(several)

Question Asked a series of questions on method details

requested method validation data for all methods used in

the analytical control strategy

Answer

- Provided copies of the methods and answered the specific

detail questions requested

- Some requests have included providing raw data (eg real

weight of reference standard and sample used) from validation

- This detail is requested as a substitute for in-country testing

thus preventing the need for in-country (repeat) testing

- The procedures are not considered ldquopart of the licenserdquo

Result Success

Method detail (South Korea)

Question Detailed test methods for API

Answer

- Provided descriptions of the assays but not copies of the methods

- These are not considered ldquopart of the licenserdquo (eg The detailed test

methods for Drug Substance are supplied as a reference The

information provided in Module 3 Section 32S42 Analytical

Procedures is considered to contain the regulatory information and

requirements)

Result Success

Detailed data (several)

Question Provide chromatograms and electropherograms for all

stability timepoints

Answer

- Provided chromatogramselectropherograms sometimes providing only

one lot instead of three lots

Result Success

Conclusions

Understanding analytical methods including real time

assessments of variability are becoming increasingly

important

The trends toward increased globalization will create

additional work and challenge for analytical professionals

Global Emerging Markets will become a larger portion of

the work due to increasing complexity in these markets

Acknowledgements

Catherine Anderson

Helena Madden

Sue Stella

Guidance list (non-inclusive) Region Topic ASEAN ASEAN GUIDELINE ON SUBMISSION OF MANUFACTURING PROCESS VALIDATION DATA FOR DRUG REGISTRATION

httpwwwhsagovsgpublishetcmedialibhsa_libraryhealth_products_regulationwestern_medicinesfiles_guidelinesPar96657FiledatA

SEAN20PV20(Version2031)20Main20Guide20without20annexespdf ASEAN VARIATION GUIDELINE FOR PHARMACEUTICAL PRODUCTS

httpwwwfdagovphattachmentsarticle95567ASEAN20Variation20Guideline20for20Pharmaceutical20Products20Final20

Draft207220(2013)pdf Thailand QampA on ASEAN Analytical Validation

httpwwwhsagovsgpublishetcmedialibhsa_libraryhealth_products_regulationwestern_medicinesfiles_guidelinesPar98887FiledatQ

ampA20analytical20validation-25jun55pdf ASEAN website with links to several guidances

httpwwwaseanorgcommunitiesasean-economic-communityitemharmonization-of-standards-and-technical-requirements-in-asean Brazil Resolution RDC No 27

httpwwwemergogroupcomfilesbrazil-resolution-rdc-no-27-21-june-2011pdf

Establishes Minimum Requirements for the Validation of Bioanalytical Methods Used in Pre- and Post-Marketing Studies

The validation of the analytical methods (Resolution RE 899 (IDRAC 39212) of 29-May-20033 and Resolution RDC 27 (IDRAC 143541) of

17-May-2012) is mandatory whenever the method is an in-house method or it is not described in pharmacopeias accepted by ANVISA Resolution RDC No 17

httpwwwabiquifiorgbrlegislacaoanvisaingles_rdc17pdf

16-Apr-2010 presents detailed guidelines about the validation and qualification requirements in the pharmaceutical industry as part of the

Good Manufacturing Practices Regulation Australia Note for Guidance on Validation of Analytical Procedures Text and Methodology

CPMPICH38195 (pdf183kb)

Japan Excerpt from presentation Japan has no guidance for bioanalytical method validation The answers in these slides are the results of the

discussion in the JBF kickoff meeting on March 30 (2011)1048579

httpwwwnihsgojpdrugBMVMontreal20110414_katoripdf Malaysia httpportalbpfkgovmyaeimagesFileAnalytical_Validation_Documents_of_Injections_Submission_Guidelinespdf Singapore ANALYTICAL METHOD VALIDATION

httpwwwhsagovsgpublishetcmedialibhsa_libraryhealth_products_regulationgmpfiles_1Par23186FiledatGUIDE-MQA-012A-

004pdf

Page 17: Capillary Electrophoresis in Global Emerging Markets: …c.ymcdn.com/sites/casss.site-ym.com/resource/resmgr/CE_Pharm...manufacturing process, ... From ASEAN Guideline on Analytical

Characteristics of GEM Regulatory Agencies

Many markets expect a major market (eg US or EMA)

approval before filing

- This facilitates approval in these countries

- Notable exceptions South Africa Brazil

Requirements and expertise can vary widely but both

are increasing

- Example Azerbaijan vs Russia vs India

- Example HSA (Singapore)

GEM Challenges

Regulations are evolving

- Advances ICH Pharmaceutical Inspection Coop Scheme

Regulations and guidelines (along with unstated

expectations) are not globally harmonized - Many country or region-specific requirements and interpretation of

guidance

- Pharmacopeia standards differ country to country

- GMPs are not globally harmonized

- Inspections are not globally harmonized

- Differences exist for reviewapproval times clinical trial application

content specification

- Approval of changes is not harmonized

- Post approval reporting requirements are not harmonized

18

GEM Challenges

Increasing complexity with foreign countries

bull Language time zones culture FMAs in-country testing

availability of instrumentation technical savvy

New requirements for some GEM countries

IP issues

Inspections

Multiple approved dossier versions for a single drug

- Multiple specifications multiple item codes different CoAs

different responses to questions

Overall Global CTD not possible

Understanding both the intent and expectations of

questions

19

In-country testing

Many countries require in country testing either before

approval or after launch of the product

Capillary electrophoresis (among other methodologies)

can be a challenge for some markets

Methods need to be robust () to facilitate transfer to

these markets

In-country testing (example)

Country Mandatory Requirement

Small Molecules Biologicals

Full vs Partial testing Local vs Contract Lab

Argentina Yes Yes Full Local Lab mandated

Brazil Yes NA Full Local Lab mandated

Chile Yes Yes Partial is possible Can be contracted out

Uruguay Yes Yes Theoretically full testing selected possible Can be contracted out

Mexico Yes Yes Full Testing (for n=20 batches) Then request a

reduction If tests are too expensive or require

sophisticated equipment reduction is possible

Testing is exempted for orphan drugs

Can be contracted out

Russia Yes Yes Full testing for new registrations Laboratory assigned by

MoH

Turkey Yes Yes Tests performed are based on the product but

normally these include Biological Dissolution

Physical physicochemical controls Content

uniformity amount Microbiological purity and ID

Official analysis institution

of TMOH

Ukraine Yes Yes Full testing State local laboratory

assigned by the MoH

Israel Yes Yes Full testing for the first imported batch and then

upon MoH request

Testing carried out by

MOH Lab

Other countries requiring testing Costa Rica DR El Salvador Ecuador Guatemala Honduras

Nicaragua Panama South Korea etc

GEM Requirements (examples) Brazil (Resolution RDC No 17 16 Apr 2010)

Article 19 Qualification and validation should not be considered only

exercises After the adoption of the qualification andor validation

report it there should have a continuous monitoring program which

must be based on periodic review [Note software validation and re-

validation is called out as a specific self-inspection item]

Article 209 Sole Paragraph Compendial analytical methods do not

require validation but before its implementation there must be

documented evidence of their suitability in the laboratory operating

conditions

Article 312 sect 3 The pharmacopoeial methods should be used for the

validation and performance of the sterility test

Article 463 sect 2 The retrospective validation is no longer encouraged

and is not applicable to the manufacture of sterile products

Article 479 sect 2 A risk assessment should be used to determine the

scope and extent of validation 22

GEM Requirements (examples) Thailand (QampA on ASEAN Analytical Validation)

6 Identify the conditionsscenarios when each of the following is

required to be conducted Full validation Revalidation Verification

Refer to 1 for Full validation and Verification According to ASEAN

Guideline revalidation may be required in the following circumstances

- Change in the synthesis of the drug substance

- Change in the composition of the finished product

- Change in the analytical procedure

From ASEAN Guideline on Analytical Validation (consistent with ICH)

The compendial methods are not required to be validated but merely

verify their suitability under actual conditions of use

23

GEM Requirements (examples) ASEAN Variation Guideline for Pharmaceutical

Products

Major Variation

- No analytical examples (not counting specification changes)

Minor Variation - Prior Approval (MiV-PA)

- Change of test procedure to non-compendial drug substance (must at

least show equivalence to former procedure) ndash MiV-PA9

- Change of in-process controls applied during the manufacture of the drug

substance (including tightening and addition of new in-process test) ndash MiV-

PA6

- Change of in-process controls applied during the manufacture of the drug

product (including tightening and addition of new in-process test) ndash MiV-

PA19

bull Interesting note Any new test method does not concern a novel non-standard

technique or a standard technique used in a novel way

Minor Variation - Notification (MiV-N)

- No analytical examples

24

GEM Requirements (examples) South Africa (Amendments)

Four categories

- Type A - amendments that may be implemented without intervention of or prior

notification to Council

- Type B - amendments that require prior notification

- Type C - amendments that require prior approval

- Type D - amendments that should be considered new applications

Type A Biological examples

- (25) Addition of release tests and or of specifications or tightening of

specifications for intermediates of the APIs

Type B Biological examples

- No analytical examples

25

GEM Requirements (examples) South Africa (Amendments)

Type C Biological examples

- (19B) Any change in analytical methods that

bull results in change(s) of specification limits or modification(s) in potency

sensitivity specificity or purity

bull establishes a new analytical method

bull deletes a specification or an analytical method

bull eliminates tests from the stability protocol or

bull alters the acceptance criteria of the stability protocol

- (20B) Any change in production processes that may

bull result in change(s) of specification limits or modification(s) in potency

sensitivity specificity or purity

bull establish a new analytical method

bull delete a specification or an analytical method

bull eliminate tests from the stability protocol or

bull alter the acceptance criteria of the stability protocol

26

Analytical Validation and Method Detail

(several)

Question Asked a series of questions on method details

requested method validation data for all methods used in

the analytical control strategy

Answer

- Provided copies of the methods and answered the specific

detail questions requested

- Some requests have included providing raw data (eg real

weight of reference standard and sample used) from validation

- This detail is requested as a substitute for in-country testing

thus preventing the need for in-country (repeat) testing

- The procedures are not considered ldquopart of the licenserdquo

Result Success

Method detail (South Korea)

Question Detailed test methods for API

Answer

- Provided descriptions of the assays but not copies of the methods

- These are not considered ldquopart of the licenserdquo (eg The detailed test

methods for Drug Substance are supplied as a reference The

information provided in Module 3 Section 32S42 Analytical

Procedures is considered to contain the regulatory information and

requirements)

Result Success

Detailed data (several)

Question Provide chromatograms and electropherograms for all

stability timepoints

Answer

- Provided chromatogramselectropherograms sometimes providing only

one lot instead of three lots

Result Success

Conclusions

Understanding analytical methods including real time

assessments of variability are becoming increasingly

important

The trends toward increased globalization will create

additional work and challenge for analytical professionals

Global Emerging Markets will become a larger portion of

the work due to increasing complexity in these markets

Acknowledgements

Catherine Anderson

Helena Madden

Sue Stella

Guidance list (non-inclusive) Region Topic ASEAN ASEAN GUIDELINE ON SUBMISSION OF MANUFACTURING PROCESS VALIDATION DATA FOR DRUG REGISTRATION

httpwwwhsagovsgpublishetcmedialibhsa_libraryhealth_products_regulationwestern_medicinesfiles_guidelinesPar96657FiledatA

SEAN20PV20(Version2031)20Main20Guide20without20annexespdf ASEAN VARIATION GUIDELINE FOR PHARMACEUTICAL PRODUCTS

httpwwwfdagovphattachmentsarticle95567ASEAN20Variation20Guideline20for20Pharmaceutical20Products20Final20

Draft207220(2013)pdf Thailand QampA on ASEAN Analytical Validation

httpwwwhsagovsgpublishetcmedialibhsa_libraryhealth_products_regulationwestern_medicinesfiles_guidelinesPar98887FiledatQ

ampA20analytical20validation-25jun55pdf ASEAN website with links to several guidances

httpwwwaseanorgcommunitiesasean-economic-communityitemharmonization-of-standards-and-technical-requirements-in-asean Brazil Resolution RDC No 27

httpwwwemergogroupcomfilesbrazil-resolution-rdc-no-27-21-june-2011pdf

Establishes Minimum Requirements for the Validation of Bioanalytical Methods Used in Pre- and Post-Marketing Studies

The validation of the analytical methods (Resolution RE 899 (IDRAC 39212) of 29-May-20033 and Resolution RDC 27 (IDRAC 143541) of

17-May-2012) is mandatory whenever the method is an in-house method or it is not described in pharmacopeias accepted by ANVISA Resolution RDC No 17

httpwwwabiquifiorgbrlegislacaoanvisaingles_rdc17pdf

16-Apr-2010 presents detailed guidelines about the validation and qualification requirements in the pharmaceutical industry as part of the

Good Manufacturing Practices Regulation Australia Note for Guidance on Validation of Analytical Procedures Text and Methodology

CPMPICH38195 (pdf183kb)

Japan Excerpt from presentation Japan has no guidance for bioanalytical method validation The answers in these slides are the results of the

discussion in the JBF kickoff meeting on March 30 (2011)1048579

httpwwwnihsgojpdrugBMVMontreal20110414_katoripdf Malaysia httpportalbpfkgovmyaeimagesFileAnalytical_Validation_Documents_of_Injections_Submission_Guidelinespdf Singapore ANALYTICAL METHOD VALIDATION

httpwwwhsagovsgpublishetcmedialibhsa_libraryhealth_products_regulationgmpfiles_1Par23186FiledatGUIDE-MQA-012A-

004pdf

Page 18: Capillary Electrophoresis in Global Emerging Markets: …c.ymcdn.com/sites/casss.site-ym.com/resource/resmgr/CE_Pharm...manufacturing process, ... From ASEAN Guideline on Analytical

GEM Challenges

Regulations are evolving

- Advances ICH Pharmaceutical Inspection Coop Scheme

Regulations and guidelines (along with unstated

expectations) are not globally harmonized - Many country or region-specific requirements and interpretation of

guidance

- Pharmacopeia standards differ country to country

- GMPs are not globally harmonized

- Inspections are not globally harmonized

- Differences exist for reviewapproval times clinical trial application

content specification

- Approval of changes is not harmonized

- Post approval reporting requirements are not harmonized

18

GEM Challenges

Increasing complexity with foreign countries

bull Language time zones culture FMAs in-country testing

availability of instrumentation technical savvy

New requirements for some GEM countries

IP issues

Inspections

Multiple approved dossier versions for a single drug

- Multiple specifications multiple item codes different CoAs

different responses to questions

Overall Global CTD not possible

Understanding both the intent and expectations of

questions

19

In-country testing

Many countries require in country testing either before

approval or after launch of the product

Capillary electrophoresis (among other methodologies)

can be a challenge for some markets

Methods need to be robust () to facilitate transfer to

these markets

In-country testing (example)

Country Mandatory Requirement

Small Molecules Biologicals

Full vs Partial testing Local vs Contract Lab

Argentina Yes Yes Full Local Lab mandated

Brazil Yes NA Full Local Lab mandated

Chile Yes Yes Partial is possible Can be contracted out

Uruguay Yes Yes Theoretically full testing selected possible Can be contracted out

Mexico Yes Yes Full Testing (for n=20 batches) Then request a

reduction If tests are too expensive or require

sophisticated equipment reduction is possible

Testing is exempted for orphan drugs

Can be contracted out

Russia Yes Yes Full testing for new registrations Laboratory assigned by

MoH

Turkey Yes Yes Tests performed are based on the product but

normally these include Biological Dissolution

Physical physicochemical controls Content

uniformity amount Microbiological purity and ID

Official analysis institution

of TMOH

Ukraine Yes Yes Full testing State local laboratory

assigned by the MoH

Israel Yes Yes Full testing for the first imported batch and then

upon MoH request

Testing carried out by

MOH Lab

Other countries requiring testing Costa Rica DR El Salvador Ecuador Guatemala Honduras

Nicaragua Panama South Korea etc

GEM Requirements (examples) Brazil (Resolution RDC No 17 16 Apr 2010)

Article 19 Qualification and validation should not be considered only

exercises After the adoption of the qualification andor validation

report it there should have a continuous monitoring program which

must be based on periodic review [Note software validation and re-

validation is called out as a specific self-inspection item]

Article 209 Sole Paragraph Compendial analytical methods do not

require validation but before its implementation there must be

documented evidence of their suitability in the laboratory operating

conditions

Article 312 sect 3 The pharmacopoeial methods should be used for the

validation and performance of the sterility test

Article 463 sect 2 The retrospective validation is no longer encouraged

and is not applicable to the manufacture of sterile products

Article 479 sect 2 A risk assessment should be used to determine the

scope and extent of validation 22

GEM Requirements (examples) Thailand (QampA on ASEAN Analytical Validation)

6 Identify the conditionsscenarios when each of the following is

required to be conducted Full validation Revalidation Verification

Refer to 1 for Full validation and Verification According to ASEAN

Guideline revalidation may be required in the following circumstances

- Change in the synthesis of the drug substance

- Change in the composition of the finished product

- Change in the analytical procedure

From ASEAN Guideline on Analytical Validation (consistent with ICH)

The compendial methods are not required to be validated but merely

verify their suitability under actual conditions of use

23

GEM Requirements (examples) ASEAN Variation Guideline for Pharmaceutical

Products

Major Variation

- No analytical examples (not counting specification changes)

Minor Variation - Prior Approval (MiV-PA)

- Change of test procedure to non-compendial drug substance (must at

least show equivalence to former procedure) ndash MiV-PA9

- Change of in-process controls applied during the manufacture of the drug

substance (including tightening and addition of new in-process test) ndash MiV-

PA6

- Change of in-process controls applied during the manufacture of the drug

product (including tightening and addition of new in-process test) ndash MiV-

PA19

bull Interesting note Any new test method does not concern a novel non-standard

technique or a standard technique used in a novel way

Minor Variation - Notification (MiV-N)

- No analytical examples

24

GEM Requirements (examples) South Africa (Amendments)

Four categories

- Type A - amendments that may be implemented without intervention of or prior

notification to Council

- Type B - amendments that require prior notification

- Type C - amendments that require prior approval

- Type D - amendments that should be considered new applications

Type A Biological examples

- (25) Addition of release tests and or of specifications or tightening of

specifications for intermediates of the APIs

Type B Biological examples

- No analytical examples

25

GEM Requirements (examples) South Africa (Amendments)

Type C Biological examples

- (19B) Any change in analytical methods that

bull results in change(s) of specification limits or modification(s) in potency

sensitivity specificity or purity

bull establishes a new analytical method

bull deletes a specification or an analytical method

bull eliminates tests from the stability protocol or

bull alters the acceptance criteria of the stability protocol

- (20B) Any change in production processes that may

bull result in change(s) of specification limits or modification(s) in potency

sensitivity specificity or purity

bull establish a new analytical method

bull delete a specification or an analytical method

bull eliminate tests from the stability protocol or

bull alter the acceptance criteria of the stability protocol

26

Analytical Validation and Method Detail

(several)

Question Asked a series of questions on method details

requested method validation data for all methods used in

the analytical control strategy

Answer

- Provided copies of the methods and answered the specific

detail questions requested

- Some requests have included providing raw data (eg real

weight of reference standard and sample used) from validation

- This detail is requested as a substitute for in-country testing

thus preventing the need for in-country (repeat) testing

- The procedures are not considered ldquopart of the licenserdquo

Result Success

Method detail (South Korea)

Question Detailed test methods for API

Answer

- Provided descriptions of the assays but not copies of the methods

- These are not considered ldquopart of the licenserdquo (eg The detailed test

methods for Drug Substance are supplied as a reference The

information provided in Module 3 Section 32S42 Analytical

Procedures is considered to contain the regulatory information and

requirements)

Result Success

Detailed data (several)

Question Provide chromatograms and electropherograms for all

stability timepoints

Answer

- Provided chromatogramselectropherograms sometimes providing only

one lot instead of three lots

Result Success

Conclusions

Understanding analytical methods including real time

assessments of variability are becoming increasingly

important

The trends toward increased globalization will create

additional work and challenge for analytical professionals

Global Emerging Markets will become a larger portion of

the work due to increasing complexity in these markets

Acknowledgements

Catherine Anderson

Helena Madden

Sue Stella

Guidance list (non-inclusive) Region Topic ASEAN ASEAN GUIDELINE ON SUBMISSION OF MANUFACTURING PROCESS VALIDATION DATA FOR DRUG REGISTRATION

httpwwwhsagovsgpublishetcmedialibhsa_libraryhealth_products_regulationwestern_medicinesfiles_guidelinesPar96657FiledatA

SEAN20PV20(Version2031)20Main20Guide20without20annexespdf ASEAN VARIATION GUIDELINE FOR PHARMACEUTICAL PRODUCTS

httpwwwfdagovphattachmentsarticle95567ASEAN20Variation20Guideline20for20Pharmaceutical20Products20Final20

Draft207220(2013)pdf Thailand QampA on ASEAN Analytical Validation

httpwwwhsagovsgpublishetcmedialibhsa_libraryhealth_products_regulationwestern_medicinesfiles_guidelinesPar98887FiledatQ

ampA20analytical20validation-25jun55pdf ASEAN website with links to several guidances

httpwwwaseanorgcommunitiesasean-economic-communityitemharmonization-of-standards-and-technical-requirements-in-asean Brazil Resolution RDC No 27

httpwwwemergogroupcomfilesbrazil-resolution-rdc-no-27-21-june-2011pdf

Establishes Minimum Requirements for the Validation of Bioanalytical Methods Used in Pre- and Post-Marketing Studies

The validation of the analytical methods (Resolution RE 899 (IDRAC 39212) of 29-May-20033 and Resolution RDC 27 (IDRAC 143541) of

17-May-2012) is mandatory whenever the method is an in-house method or it is not described in pharmacopeias accepted by ANVISA Resolution RDC No 17

httpwwwabiquifiorgbrlegislacaoanvisaingles_rdc17pdf

16-Apr-2010 presents detailed guidelines about the validation and qualification requirements in the pharmaceutical industry as part of the

Good Manufacturing Practices Regulation Australia Note for Guidance on Validation of Analytical Procedures Text and Methodology

CPMPICH38195 (pdf183kb)

Japan Excerpt from presentation Japan has no guidance for bioanalytical method validation The answers in these slides are the results of the

discussion in the JBF kickoff meeting on March 30 (2011)1048579

httpwwwnihsgojpdrugBMVMontreal20110414_katoripdf Malaysia httpportalbpfkgovmyaeimagesFileAnalytical_Validation_Documents_of_Injections_Submission_Guidelinespdf Singapore ANALYTICAL METHOD VALIDATION

httpwwwhsagovsgpublishetcmedialibhsa_libraryhealth_products_regulationgmpfiles_1Par23186FiledatGUIDE-MQA-012A-

004pdf

Page 19: Capillary Electrophoresis in Global Emerging Markets: …c.ymcdn.com/sites/casss.site-ym.com/resource/resmgr/CE_Pharm...manufacturing process, ... From ASEAN Guideline on Analytical

GEM Challenges

Increasing complexity with foreign countries

bull Language time zones culture FMAs in-country testing

availability of instrumentation technical savvy

New requirements for some GEM countries

IP issues

Inspections

Multiple approved dossier versions for a single drug

- Multiple specifications multiple item codes different CoAs

different responses to questions

Overall Global CTD not possible

Understanding both the intent and expectations of

questions

19

In-country testing

Many countries require in country testing either before

approval or after launch of the product

Capillary electrophoresis (among other methodologies)

can be a challenge for some markets

Methods need to be robust () to facilitate transfer to

these markets

In-country testing (example)

Country Mandatory Requirement

Small Molecules Biologicals

Full vs Partial testing Local vs Contract Lab

Argentina Yes Yes Full Local Lab mandated

Brazil Yes NA Full Local Lab mandated

Chile Yes Yes Partial is possible Can be contracted out

Uruguay Yes Yes Theoretically full testing selected possible Can be contracted out

Mexico Yes Yes Full Testing (for n=20 batches) Then request a

reduction If tests are too expensive or require

sophisticated equipment reduction is possible

Testing is exempted for orphan drugs

Can be contracted out

Russia Yes Yes Full testing for new registrations Laboratory assigned by

MoH

Turkey Yes Yes Tests performed are based on the product but

normally these include Biological Dissolution

Physical physicochemical controls Content

uniformity amount Microbiological purity and ID

Official analysis institution

of TMOH

Ukraine Yes Yes Full testing State local laboratory

assigned by the MoH

Israel Yes Yes Full testing for the first imported batch and then

upon MoH request

Testing carried out by

MOH Lab

Other countries requiring testing Costa Rica DR El Salvador Ecuador Guatemala Honduras

Nicaragua Panama South Korea etc

GEM Requirements (examples) Brazil (Resolution RDC No 17 16 Apr 2010)

Article 19 Qualification and validation should not be considered only

exercises After the adoption of the qualification andor validation

report it there should have a continuous monitoring program which

must be based on periodic review [Note software validation and re-

validation is called out as a specific self-inspection item]

Article 209 Sole Paragraph Compendial analytical methods do not

require validation but before its implementation there must be

documented evidence of their suitability in the laboratory operating

conditions

Article 312 sect 3 The pharmacopoeial methods should be used for the

validation and performance of the sterility test

Article 463 sect 2 The retrospective validation is no longer encouraged

and is not applicable to the manufacture of sterile products

Article 479 sect 2 A risk assessment should be used to determine the

scope and extent of validation 22

GEM Requirements (examples) Thailand (QampA on ASEAN Analytical Validation)

6 Identify the conditionsscenarios when each of the following is

required to be conducted Full validation Revalidation Verification

Refer to 1 for Full validation and Verification According to ASEAN

Guideline revalidation may be required in the following circumstances

- Change in the synthesis of the drug substance

- Change in the composition of the finished product

- Change in the analytical procedure

From ASEAN Guideline on Analytical Validation (consistent with ICH)

The compendial methods are not required to be validated but merely

verify their suitability under actual conditions of use

23

GEM Requirements (examples) ASEAN Variation Guideline for Pharmaceutical

Products

Major Variation

- No analytical examples (not counting specification changes)

Minor Variation - Prior Approval (MiV-PA)

- Change of test procedure to non-compendial drug substance (must at

least show equivalence to former procedure) ndash MiV-PA9

- Change of in-process controls applied during the manufacture of the drug

substance (including tightening and addition of new in-process test) ndash MiV-

PA6

- Change of in-process controls applied during the manufacture of the drug

product (including tightening and addition of new in-process test) ndash MiV-

PA19

bull Interesting note Any new test method does not concern a novel non-standard

technique or a standard technique used in a novel way

Minor Variation - Notification (MiV-N)

- No analytical examples

24

GEM Requirements (examples) South Africa (Amendments)

Four categories

- Type A - amendments that may be implemented without intervention of or prior

notification to Council

- Type B - amendments that require prior notification

- Type C - amendments that require prior approval

- Type D - amendments that should be considered new applications

Type A Biological examples

- (25) Addition of release tests and or of specifications or tightening of

specifications for intermediates of the APIs

Type B Biological examples

- No analytical examples

25

GEM Requirements (examples) South Africa (Amendments)

Type C Biological examples

- (19B) Any change in analytical methods that

bull results in change(s) of specification limits or modification(s) in potency

sensitivity specificity or purity

bull establishes a new analytical method

bull deletes a specification or an analytical method

bull eliminates tests from the stability protocol or

bull alters the acceptance criteria of the stability protocol

- (20B) Any change in production processes that may

bull result in change(s) of specification limits or modification(s) in potency

sensitivity specificity or purity

bull establish a new analytical method

bull delete a specification or an analytical method

bull eliminate tests from the stability protocol or

bull alter the acceptance criteria of the stability protocol

26

Analytical Validation and Method Detail

(several)

Question Asked a series of questions on method details

requested method validation data for all methods used in

the analytical control strategy

Answer

- Provided copies of the methods and answered the specific

detail questions requested

- Some requests have included providing raw data (eg real

weight of reference standard and sample used) from validation

- This detail is requested as a substitute for in-country testing

thus preventing the need for in-country (repeat) testing

- The procedures are not considered ldquopart of the licenserdquo

Result Success

Method detail (South Korea)

Question Detailed test methods for API

Answer

- Provided descriptions of the assays but not copies of the methods

- These are not considered ldquopart of the licenserdquo (eg The detailed test

methods for Drug Substance are supplied as a reference The

information provided in Module 3 Section 32S42 Analytical

Procedures is considered to contain the regulatory information and

requirements)

Result Success

Detailed data (several)

Question Provide chromatograms and electropherograms for all

stability timepoints

Answer

- Provided chromatogramselectropherograms sometimes providing only

one lot instead of three lots

Result Success

Conclusions

Understanding analytical methods including real time

assessments of variability are becoming increasingly

important

The trends toward increased globalization will create

additional work and challenge for analytical professionals

Global Emerging Markets will become a larger portion of

the work due to increasing complexity in these markets

Acknowledgements

Catherine Anderson

Helena Madden

Sue Stella

Guidance list (non-inclusive) Region Topic ASEAN ASEAN GUIDELINE ON SUBMISSION OF MANUFACTURING PROCESS VALIDATION DATA FOR DRUG REGISTRATION

httpwwwhsagovsgpublishetcmedialibhsa_libraryhealth_products_regulationwestern_medicinesfiles_guidelinesPar96657FiledatA

SEAN20PV20(Version2031)20Main20Guide20without20annexespdf ASEAN VARIATION GUIDELINE FOR PHARMACEUTICAL PRODUCTS

httpwwwfdagovphattachmentsarticle95567ASEAN20Variation20Guideline20for20Pharmaceutical20Products20Final20

Draft207220(2013)pdf Thailand QampA on ASEAN Analytical Validation

httpwwwhsagovsgpublishetcmedialibhsa_libraryhealth_products_regulationwestern_medicinesfiles_guidelinesPar98887FiledatQ

ampA20analytical20validation-25jun55pdf ASEAN website with links to several guidances

httpwwwaseanorgcommunitiesasean-economic-communityitemharmonization-of-standards-and-technical-requirements-in-asean Brazil Resolution RDC No 27

httpwwwemergogroupcomfilesbrazil-resolution-rdc-no-27-21-june-2011pdf

Establishes Minimum Requirements for the Validation of Bioanalytical Methods Used in Pre- and Post-Marketing Studies

The validation of the analytical methods (Resolution RE 899 (IDRAC 39212) of 29-May-20033 and Resolution RDC 27 (IDRAC 143541) of

17-May-2012) is mandatory whenever the method is an in-house method or it is not described in pharmacopeias accepted by ANVISA Resolution RDC No 17

httpwwwabiquifiorgbrlegislacaoanvisaingles_rdc17pdf

16-Apr-2010 presents detailed guidelines about the validation and qualification requirements in the pharmaceutical industry as part of the

Good Manufacturing Practices Regulation Australia Note for Guidance on Validation of Analytical Procedures Text and Methodology

CPMPICH38195 (pdf183kb)

Japan Excerpt from presentation Japan has no guidance for bioanalytical method validation The answers in these slides are the results of the

discussion in the JBF kickoff meeting on March 30 (2011)1048579

httpwwwnihsgojpdrugBMVMontreal20110414_katoripdf Malaysia httpportalbpfkgovmyaeimagesFileAnalytical_Validation_Documents_of_Injections_Submission_Guidelinespdf Singapore ANALYTICAL METHOD VALIDATION

httpwwwhsagovsgpublishetcmedialibhsa_libraryhealth_products_regulationgmpfiles_1Par23186FiledatGUIDE-MQA-012A-

004pdf

Page 20: Capillary Electrophoresis in Global Emerging Markets: …c.ymcdn.com/sites/casss.site-ym.com/resource/resmgr/CE_Pharm...manufacturing process, ... From ASEAN Guideline on Analytical

In-country testing

Many countries require in country testing either before

approval or after launch of the product

Capillary electrophoresis (among other methodologies)

can be a challenge for some markets

Methods need to be robust () to facilitate transfer to

these markets

In-country testing (example)

Country Mandatory Requirement

Small Molecules Biologicals

Full vs Partial testing Local vs Contract Lab

Argentina Yes Yes Full Local Lab mandated

Brazil Yes NA Full Local Lab mandated

Chile Yes Yes Partial is possible Can be contracted out

Uruguay Yes Yes Theoretically full testing selected possible Can be contracted out

Mexico Yes Yes Full Testing (for n=20 batches) Then request a

reduction If tests are too expensive or require

sophisticated equipment reduction is possible

Testing is exempted for orphan drugs

Can be contracted out

Russia Yes Yes Full testing for new registrations Laboratory assigned by

MoH

Turkey Yes Yes Tests performed are based on the product but

normally these include Biological Dissolution

Physical physicochemical controls Content

uniformity amount Microbiological purity and ID

Official analysis institution

of TMOH

Ukraine Yes Yes Full testing State local laboratory

assigned by the MoH

Israel Yes Yes Full testing for the first imported batch and then

upon MoH request

Testing carried out by

MOH Lab

Other countries requiring testing Costa Rica DR El Salvador Ecuador Guatemala Honduras

Nicaragua Panama South Korea etc

GEM Requirements (examples) Brazil (Resolution RDC No 17 16 Apr 2010)

Article 19 Qualification and validation should not be considered only

exercises After the adoption of the qualification andor validation

report it there should have a continuous monitoring program which

must be based on periodic review [Note software validation and re-

validation is called out as a specific self-inspection item]

Article 209 Sole Paragraph Compendial analytical methods do not

require validation but before its implementation there must be

documented evidence of their suitability in the laboratory operating

conditions

Article 312 sect 3 The pharmacopoeial methods should be used for the

validation and performance of the sterility test

Article 463 sect 2 The retrospective validation is no longer encouraged

and is not applicable to the manufacture of sterile products

Article 479 sect 2 A risk assessment should be used to determine the

scope and extent of validation 22

GEM Requirements (examples) Thailand (QampA on ASEAN Analytical Validation)

6 Identify the conditionsscenarios when each of the following is

required to be conducted Full validation Revalidation Verification

Refer to 1 for Full validation and Verification According to ASEAN

Guideline revalidation may be required in the following circumstances

- Change in the synthesis of the drug substance

- Change in the composition of the finished product

- Change in the analytical procedure

From ASEAN Guideline on Analytical Validation (consistent with ICH)

The compendial methods are not required to be validated but merely

verify their suitability under actual conditions of use

23

GEM Requirements (examples) ASEAN Variation Guideline for Pharmaceutical

Products

Major Variation

- No analytical examples (not counting specification changes)

Minor Variation - Prior Approval (MiV-PA)

- Change of test procedure to non-compendial drug substance (must at

least show equivalence to former procedure) ndash MiV-PA9

- Change of in-process controls applied during the manufacture of the drug

substance (including tightening and addition of new in-process test) ndash MiV-

PA6

- Change of in-process controls applied during the manufacture of the drug

product (including tightening and addition of new in-process test) ndash MiV-

PA19

bull Interesting note Any new test method does not concern a novel non-standard

technique or a standard technique used in a novel way

Minor Variation - Notification (MiV-N)

- No analytical examples

24

GEM Requirements (examples) South Africa (Amendments)

Four categories

- Type A - amendments that may be implemented without intervention of or prior

notification to Council

- Type B - amendments that require prior notification

- Type C - amendments that require prior approval

- Type D - amendments that should be considered new applications

Type A Biological examples

- (25) Addition of release tests and or of specifications or tightening of

specifications for intermediates of the APIs

Type B Biological examples

- No analytical examples

25

GEM Requirements (examples) South Africa (Amendments)

Type C Biological examples

- (19B) Any change in analytical methods that

bull results in change(s) of specification limits or modification(s) in potency

sensitivity specificity or purity

bull establishes a new analytical method

bull deletes a specification or an analytical method

bull eliminates tests from the stability protocol or

bull alters the acceptance criteria of the stability protocol

- (20B) Any change in production processes that may

bull result in change(s) of specification limits or modification(s) in potency

sensitivity specificity or purity

bull establish a new analytical method

bull delete a specification or an analytical method

bull eliminate tests from the stability protocol or

bull alter the acceptance criteria of the stability protocol

26

Analytical Validation and Method Detail

(several)

Question Asked a series of questions on method details

requested method validation data for all methods used in

the analytical control strategy

Answer

- Provided copies of the methods and answered the specific

detail questions requested

- Some requests have included providing raw data (eg real

weight of reference standard and sample used) from validation

- This detail is requested as a substitute for in-country testing

thus preventing the need for in-country (repeat) testing

- The procedures are not considered ldquopart of the licenserdquo

Result Success

Method detail (South Korea)

Question Detailed test methods for API

Answer

- Provided descriptions of the assays but not copies of the methods

- These are not considered ldquopart of the licenserdquo (eg The detailed test

methods for Drug Substance are supplied as a reference The

information provided in Module 3 Section 32S42 Analytical

Procedures is considered to contain the regulatory information and

requirements)

Result Success

Detailed data (several)

Question Provide chromatograms and electropherograms for all

stability timepoints

Answer

- Provided chromatogramselectropherograms sometimes providing only

one lot instead of three lots

Result Success

Conclusions

Understanding analytical methods including real time

assessments of variability are becoming increasingly

important

The trends toward increased globalization will create

additional work and challenge for analytical professionals

Global Emerging Markets will become a larger portion of

the work due to increasing complexity in these markets

Acknowledgements

Catherine Anderson

Helena Madden

Sue Stella

Guidance list (non-inclusive) Region Topic ASEAN ASEAN GUIDELINE ON SUBMISSION OF MANUFACTURING PROCESS VALIDATION DATA FOR DRUG REGISTRATION

httpwwwhsagovsgpublishetcmedialibhsa_libraryhealth_products_regulationwestern_medicinesfiles_guidelinesPar96657FiledatA

SEAN20PV20(Version2031)20Main20Guide20without20annexespdf ASEAN VARIATION GUIDELINE FOR PHARMACEUTICAL PRODUCTS

httpwwwfdagovphattachmentsarticle95567ASEAN20Variation20Guideline20for20Pharmaceutical20Products20Final20

Draft207220(2013)pdf Thailand QampA on ASEAN Analytical Validation

httpwwwhsagovsgpublishetcmedialibhsa_libraryhealth_products_regulationwestern_medicinesfiles_guidelinesPar98887FiledatQ

ampA20analytical20validation-25jun55pdf ASEAN website with links to several guidances

httpwwwaseanorgcommunitiesasean-economic-communityitemharmonization-of-standards-and-technical-requirements-in-asean Brazil Resolution RDC No 27

httpwwwemergogroupcomfilesbrazil-resolution-rdc-no-27-21-june-2011pdf

Establishes Minimum Requirements for the Validation of Bioanalytical Methods Used in Pre- and Post-Marketing Studies

The validation of the analytical methods (Resolution RE 899 (IDRAC 39212) of 29-May-20033 and Resolution RDC 27 (IDRAC 143541) of

17-May-2012) is mandatory whenever the method is an in-house method or it is not described in pharmacopeias accepted by ANVISA Resolution RDC No 17

httpwwwabiquifiorgbrlegislacaoanvisaingles_rdc17pdf

16-Apr-2010 presents detailed guidelines about the validation and qualification requirements in the pharmaceutical industry as part of the

Good Manufacturing Practices Regulation Australia Note for Guidance on Validation of Analytical Procedures Text and Methodology

CPMPICH38195 (pdf183kb)

Japan Excerpt from presentation Japan has no guidance for bioanalytical method validation The answers in these slides are the results of the

discussion in the JBF kickoff meeting on March 30 (2011)1048579

httpwwwnihsgojpdrugBMVMontreal20110414_katoripdf Malaysia httpportalbpfkgovmyaeimagesFileAnalytical_Validation_Documents_of_Injections_Submission_Guidelinespdf Singapore ANALYTICAL METHOD VALIDATION

httpwwwhsagovsgpublishetcmedialibhsa_libraryhealth_products_regulationgmpfiles_1Par23186FiledatGUIDE-MQA-012A-

004pdf

Page 21: Capillary Electrophoresis in Global Emerging Markets: …c.ymcdn.com/sites/casss.site-ym.com/resource/resmgr/CE_Pharm...manufacturing process, ... From ASEAN Guideline on Analytical

In-country testing (example)

Country Mandatory Requirement

Small Molecules Biologicals

Full vs Partial testing Local vs Contract Lab

Argentina Yes Yes Full Local Lab mandated

Brazil Yes NA Full Local Lab mandated

Chile Yes Yes Partial is possible Can be contracted out

Uruguay Yes Yes Theoretically full testing selected possible Can be contracted out

Mexico Yes Yes Full Testing (for n=20 batches) Then request a

reduction If tests are too expensive or require

sophisticated equipment reduction is possible

Testing is exempted for orphan drugs

Can be contracted out

Russia Yes Yes Full testing for new registrations Laboratory assigned by

MoH

Turkey Yes Yes Tests performed are based on the product but

normally these include Biological Dissolution

Physical physicochemical controls Content

uniformity amount Microbiological purity and ID

Official analysis institution

of TMOH

Ukraine Yes Yes Full testing State local laboratory

assigned by the MoH

Israel Yes Yes Full testing for the first imported batch and then

upon MoH request

Testing carried out by

MOH Lab

Other countries requiring testing Costa Rica DR El Salvador Ecuador Guatemala Honduras

Nicaragua Panama South Korea etc

GEM Requirements (examples) Brazil (Resolution RDC No 17 16 Apr 2010)

Article 19 Qualification and validation should not be considered only

exercises After the adoption of the qualification andor validation

report it there should have a continuous monitoring program which

must be based on periodic review [Note software validation and re-

validation is called out as a specific self-inspection item]

Article 209 Sole Paragraph Compendial analytical methods do not

require validation but before its implementation there must be

documented evidence of their suitability in the laboratory operating

conditions

Article 312 sect 3 The pharmacopoeial methods should be used for the

validation and performance of the sterility test

Article 463 sect 2 The retrospective validation is no longer encouraged

and is not applicable to the manufacture of sterile products

Article 479 sect 2 A risk assessment should be used to determine the

scope and extent of validation 22

GEM Requirements (examples) Thailand (QampA on ASEAN Analytical Validation)

6 Identify the conditionsscenarios when each of the following is

required to be conducted Full validation Revalidation Verification

Refer to 1 for Full validation and Verification According to ASEAN

Guideline revalidation may be required in the following circumstances

- Change in the synthesis of the drug substance

- Change in the composition of the finished product

- Change in the analytical procedure

From ASEAN Guideline on Analytical Validation (consistent with ICH)

The compendial methods are not required to be validated but merely

verify their suitability under actual conditions of use

23

GEM Requirements (examples) ASEAN Variation Guideline for Pharmaceutical

Products

Major Variation

- No analytical examples (not counting specification changes)

Minor Variation - Prior Approval (MiV-PA)

- Change of test procedure to non-compendial drug substance (must at

least show equivalence to former procedure) ndash MiV-PA9

- Change of in-process controls applied during the manufacture of the drug

substance (including tightening and addition of new in-process test) ndash MiV-

PA6

- Change of in-process controls applied during the manufacture of the drug

product (including tightening and addition of new in-process test) ndash MiV-

PA19

bull Interesting note Any new test method does not concern a novel non-standard

technique or a standard technique used in a novel way

Minor Variation - Notification (MiV-N)

- No analytical examples

24

GEM Requirements (examples) South Africa (Amendments)

Four categories

- Type A - amendments that may be implemented without intervention of or prior

notification to Council

- Type B - amendments that require prior notification

- Type C - amendments that require prior approval

- Type D - amendments that should be considered new applications

Type A Biological examples

- (25) Addition of release tests and or of specifications or tightening of

specifications for intermediates of the APIs

Type B Biological examples

- No analytical examples

25

GEM Requirements (examples) South Africa (Amendments)

Type C Biological examples

- (19B) Any change in analytical methods that

bull results in change(s) of specification limits or modification(s) in potency

sensitivity specificity or purity

bull establishes a new analytical method

bull deletes a specification or an analytical method

bull eliminates tests from the stability protocol or

bull alters the acceptance criteria of the stability protocol

- (20B) Any change in production processes that may

bull result in change(s) of specification limits or modification(s) in potency

sensitivity specificity or purity

bull establish a new analytical method

bull delete a specification or an analytical method

bull eliminate tests from the stability protocol or

bull alter the acceptance criteria of the stability protocol

26

Analytical Validation and Method Detail

(several)

Question Asked a series of questions on method details

requested method validation data for all methods used in

the analytical control strategy

Answer

- Provided copies of the methods and answered the specific

detail questions requested

- Some requests have included providing raw data (eg real

weight of reference standard and sample used) from validation

- This detail is requested as a substitute for in-country testing

thus preventing the need for in-country (repeat) testing

- The procedures are not considered ldquopart of the licenserdquo

Result Success

Method detail (South Korea)

Question Detailed test methods for API

Answer

- Provided descriptions of the assays but not copies of the methods

- These are not considered ldquopart of the licenserdquo (eg The detailed test

methods for Drug Substance are supplied as a reference The

information provided in Module 3 Section 32S42 Analytical

Procedures is considered to contain the regulatory information and

requirements)

Result Success

Detailed data (several)

Question Provide chromatograms and electropherograms for all

stability timepoints

Answer

- Provided chromatogramselectropherograms sometimes providing only

one lot instead of three lots

Result Success

Conclusions

Understanding analytical methods including real time

assessments of variability are becoming increasingly

important

The trends toward increased globalization will create

additional work and challenge for analytical professionals

Global Emerging Markets will become a larger portion of

the work due to increasing complexity in these markets

Acknowledgements

Catherine Anderson

Helena Madden

Sue Stella

Guidance list (non-inclusive) Region Topic ASEAN ASEAN GUIDELINE ON SUBMISSION OF MANUFACTURING PROCESS VALIDATION DATA FOR DRUG REGISTRATION

httpwwwhsagovsgpublishetcmedialibhsa_libraryhealth_products_regulationwestern_medicinesfiles_guidelinesPar96657FiledatA

SEAN20PV20(Version2031)20Main20Guide20without20annexespdf ASEAN VARIATION GUIDELINE FOR PHARMACEUTICAL PRODUCTS

httpwwwfdagovphattachmentsarticle95567ASEAN20Variation20Guideline20for20Pharmaceutical20Products20Final20

Draft207220(2013)pdf Thailand QampA on ASEAN Analytical Validation

httpwwwhsagovsgpublishetcmedialibhsa_libraryhealth_products_regulationwestern_medicinesfiles_guidelinesPar98887FiledatQ

ampA20analytical20validation-25jun55pdf ASEAN website with links to several guidances

httpwwwaseanorgcommunitiesasean-economic-communityitemharmonization-of-standards-and-technical-requirements-in-asean Brazil Resolution RDC No 27

httpwwwemergogroupcomfilesbrazil-resolution-rdc-no-27-21-june-2011pdf

Establishes Minimum Requirements for the Validation of Bioanalytical Methods Used in Pre- and Post-Marketing Studies

The validation of the analytical methods (Resolution RE 899 (IDRAC 39212) of 29-May-20033 and Resolution RDC 27 (IDRAC 143541) of

17-May-2012) is mandatory whenever the method is an in-house method or it is not described in pharmacopeias accepted by ANVISA Resolution RDC No 17

httpwwwabiquifiorgbrlegislacaoanvisaingles_rdc17pdf

16-Apr-2010 presents detailed guidelines about the validation and qualification requirements in the pharmaceutical industry as part of the

Good Manufacturing Practices Regulation Australia Note for Guidance on Validation of Analytical Procedures Text and Methodology

CPMPICH38195 (pdf183kb)

Japan Excerpt from presentation Japan has no guidance for bioanalytical method validation The answers in these slides are the results of the

discussion in the JBF kickoff meeting on March 30 (2011)1048579

httpwwwnihsgojpdrugBMVMontreal20110414_katoripdf Malaysia httpportalbpfkgovmyaeimagesFileAnalytical_Validation_Documents_of_Injections_Submission_Guidelinespdf Singapore ANALYTICAL METHOD VALIDATION

httpwwwhsagovsgpublishetcmedialibhsa_libraryhealth_products_regulationgmpfiles_1Par23186FiledatGUIDE-MQA-012A-

004pdf

Page 22: Capillary Electrophoresis in Global Emerging Markets: …c.ymcdn.com/sites/casss.site-ym.com/resource/resmgr/CE_Pharm...manufacturing process, ... From ASEAN Guideline on Analytical

GEM Requirements (examples) Brazil (Resolution RDC No 17 16 Apr 2010)

Article 19 Qualification and validation should not be considered only

exercises After the adoption of the qualification andor validation

report it there should have a continuous monitoring program which

must be based on periodic review [Note software validation and re-

validation is called out as a specific self-inspection item]

Article 209 Sole Paragraph Compendial analytical methods do not

require validation but before its implementation there must be

documented evidence of their suitability in the laboratory operating

conditions

Article 312 sect 3 The pharmacopoeial methods should be used for the

validation and performance of the sterility test

Article 463 sect 2 The retrospective validation is no longer encouraged

and is not applicable to the manufacture of sterile products

Article 479 sect 2 A risk assessment should be used to determine the

scope and extent of validation 22

GEM Requirements (examples) Thailand (QampA on ASEAN Analytical Validation)

6 Identify the conditionsscenarios when each of the following is

required to be conducted Full validation Revalidation Verification

Refer to 1 for Full validation and Verification According to ASEAN

Guideline revalidation may be required in the following circumstances

- Change in the synthesis of the drug substance

- Change in the composition of the finished product

- Change in the analytical procedure

From ASEAN Guideline on Analytical Validation (consistent with ICH)

The compendial methods are not required to be validated but merely

verify their suitability under actual conditions of use

23

GEM Requirements (examples) ASEAN Variation Guideline for Pharmaceutical

Products

Major Variation

- No analytical examples (not counting specification changes)

Minor Variation - Prior Approval (MiV-PA)

- Change of test procedure to non-compendial drug substance (must at

least show equivalence to former procedure) ndash MiV-PA9

- Change of in-process controls applied during the manufacture of the drug

substance (including tightening and addition of new in-process test) ndash MiV-

PA6

- Change of in-process controls applied during the manufacture of the drug

product (including tightening and addition of new in-process test) ndash MiV-

PA19

bull Interesting note Any new test method does not concern a novel non-standard

technique or a standard technique used in a novel way

Minor Variation - Notification (MiV-N)

- No analytical examples

24

GEM Requirements (examples) South Africa (Amendments)

Four categories

- Type A - amendments that may be implemented without intervention of or prior

notification to Council

- Type B - amendments that require prior notification

- Type C - amendments that require prior approval

- Type D - amendments that should be considered new applications

Type A Biological examples

- (25) Addition of release tests and or of specifications or tightening of

specifications for intermediates of the APIs

Type B Biological examples

- No analytical examples

25

GEM Requirements (examples) South Africa (Amendments)

Type C Biological examples

- (19B) Any change in analytical methods that

bull results in change(s) of specification limits or modification(s) in potency

sensitivity specificity or purity

bull establishes a new analytical method

bull deletes a specification or an analytical method

bull eliminates tests from the stability protocol or

bull alters the acceptance criteria of the stability protocol

- (20B) Any change in production processes that may

bull result in change(s) of specification limits or modification(s) in potency

sensitivity specificity or purity

bull establish a new analytical method

bull delete a specification or an analytical method

bull eliminate tests from the stability protocol or

bull alter the acceptance criteria of the stability protocol

26

Analytical Validation and Method Detail

(several)

Question Asked a series of questions on method details

requested method validation data for all methods used in

the analytical control strategy

Answer

- Provided copies of the methods and answered the specific

detail questions requested

- Some requests have included providing raw data (eg real

weight of reference standard and sample used) from validation

- This detail is requested as a substitute for in-country testing

thus preventing the need for in-country (repeat) testing

- The procedures are not considered ldquopart of the licenserdquo

Result Success

Method detail (South Korea)

Question Detailed test methods for API

Answer

- Provided descriptions of the assays but not copies of the methods

- These are not considered ldquopart of the licenserdquo (eg The detailed test

methods for Drug Substance are supplied as a reference The

information provided in Module 3 Section 32S42 Analytical

Procedures is considered to contain the regulatory information and

requirements)

Result Success

Detailed data (several)

Question Provide chromatograms and electropherograms for all

stability timepoints

Answer

- Provided chromatogramselectropherograms sometimes providing only

one lot instead of three lots

Result Success

Conclusions

Understanding analytical methods including real time

assessments of variability are becoming increasingly

important

The trends toward increased globalization will create

additional work and challenge for analytical professionals

Global Emerging Markets will become a larger portion of

the work due to increasing complexity in these markets

Acknowledgements

Catherine Anderson

Helena Madden

Sue Stella

Guidance list (non-inclusive) Region Topic ASEAN ASEAN GUIDELINE ON SUBMISSION OF MANUFACTURING PROCESS VALIDATION DATA FOR DRUG REGISTRATION

httpwwwhsagovsgpublishetcmedialibhsa_libraryhealth_products_regulationwestern_medicinesfiles_guidelinesPar96657FiledatA

SEAN20PV20(Version2031)20Main20Guide20without20annexespdf ASEAN VARIATION GUIDELINE FOR PHARMACEUTICAL PRODUCTS

httpwwwfdagovphattachmentsarticle95567ASEAN20Variation20Guideline20for20Pharmaceutical20Products20Final20

Draft207220(2013)pdf Thailand QampA on ASEAN Analytical Validation

httpwwwhsagovsgpublishetcmedialibhsa_libraryhealth_products_regulationwestern_medicinesfiles_guidelinesPar98887FiledatQ

ampA20analytical20validation-25jun55pdf ASEAN website with links to several guidances

httpwwwaseanorgcommunitiesasean-economic-communityitemharmonization-of-standards-and-technical-requirements-in-asean Brazil Resolution RDC No 27

httpwwwemergogroupcomfilesbrazil-resolution-rdc-no-27-21-june-2011pdf

Establishes Minimum Requirements for the Validation of Bioanalytical Methods Used in Pre- and Post-Marketing Studies

The validation of the analytical methods (Resolution RE 899 (IDRAC 39212) of 29-May-20033 and Resolution RDC 27 (IDRAC 143541) of

17-May-2012) is mandatory whenever the method is an in-house method or it is not described in pharmacopeias accepted by ANVISA Resolution RDC No 17

httpwwwabiquifiorgbrlegislacaoanvisaingles_rdc17pdf

16-Apr-2010 presents detailed guidelines about the validation and qualification requirements in the pharmaceutical industry as part of the

Good Manufacturing Practices Regulation Australia Note for Guidance on Validation of Analytical Procedures Text and Methodology

CPMPICH38195 (pdf183kb)

Japan Excerpt from presentation Japan has no guidance for bioanalytical method validation The answers in these slides are the results of the

discussion in the JBF kickoff meeting on March 30 (2011)1048579

httpwwwnihsgojpdrugBMVMontreal20110414_katoripdf Malaysia httpportalbpfkgovmyaeimagesFileAnalytical_Validation_Documents_of_Injections_Submission_Guidelinespdf Singapore ANALYTICAL METHOD VALIDATION

httpwwwhsagovsgpublishetcmedialibhsa_libraryhealth_products_regulationgmpfiles_1Par23186FiledatGUIDE-MQA-012A-

004pdf

Page 23: Capillary Electrophoresis in Global Emerging Markets: …c.ymcdn.com/sites/casss.site-ym.com/resource/resmgr/CE_Pharm...manufacturing process, ... From ASEAN Guideline on Analytical

GEM Requirements (examples) Thailand (QampA on ASEAN Analytical Validation)

6 Identify the conditionsscenarios when each of the following is

required to be conducted Full validation Revalidation Verification

Refer to 1 for Full validation and Verification According to ASEAN

Guideline revalidation may be required in the following circumstances

- Change in the synthesis of the drug substance

- Change in the composition of the finished product

- Change in the analytical procedure

From ASEAN Guideline on Analytical Validation (consistent with ICH)

The compendial methods are not required to be validated but merely

verify their suitability under actual conditions of use

23

GEM Requirements (examples) ASEAN Variation Guideline for Pharmaceutical

Products

Major Variation

- No analytical examples (not counting specification changes)

Minor Variation - Prior Approval (MiV-PA)

- Change of test procedure to non-compendial drug substance (must at

least show equivalence to former procedure) ndash MiV-PA9

- Change of in-process controls applied during the manufacture of the drug

substance (including tightening and addition of new in-process test) ndash MiV-

PA6

- Change of in-process controls applied during the manufacture of the drug

product (including tightening and addition of new in-process test) ndash MiV-

PA19

bull Interesting note Any new test method does not concern a novel non-standard

technique or a standard technique used in a novel way

Minor Variation - Notification (MiV-N)

- No analytical examples

24

GEM Requirements (examples) South Africa (Amendments)

Four categories

- Type A - amendments that may be implemented without intervention of or prior

notification to Council

- Type B - amendments that require prior notification

- Type C - amendments that require prior approval

- Type D - amendments that should be considered new applications

Type A Biological examples

- (25) Addition of release tests and or of specifications or tightening of

specifications for intermediates of the APIs

Type B Biological examples

- No analytical examples

25

GEM Requirements (examples) South Africa (Amendments)

Type C Biological examples

- (19B) Any change in analytical methods that

bull results in change(s) of specification limits or modification(s) in potency

sensitivity specificity or purity

bull establishes a new analytical method

bull deletes a specification or an analytical method

bull eliminates tests from the stability protocol or

bull alters the acceptance criteria of the stability protocol

- (20B) Any change in production processes that may

bull result in change(s) of specification limits or modification(s) in potency

sensitivity specificity or purity

bull establish a new analytical method

bull delete a specification or an analytical method

bull eliminate tests from the stability protocol or

bull alter the acceptance criteria of the stability protocol

26

Analytical Validation and Method Detail

(several)

Question Asked a series of questions on method details

requested method validation data for all methods used in

the analytical control strategy

Answer

- Provided copies of the methods and answered the specific

detail questions requested

- Some requests have included providing raw data (eg real

weight of reference standard and sample used) from validation

- This detail is requested as a substitute for in-country testing

thus preventing the need for in-country (repeat) testing

- The procedures are not considered ldquopart of the licenserdquo

Result Success

Method detail (South Korea)

Question Detailed test methods for API

Answer

- Provided descriptions of the assays but not copies of the methods

- These are not considered ldquopart of the licenserdquo (eg The detailed test

methods for Drug Substance are supplied as a reference The

information provided in Module 3 Section 32S42 Analytical

Procedures is considered to contain the regulatory information and

requirements)

Result Success

Detailed data (several)

Question Provide chromatograms and electropherograms for all

stability timepoints

Answer

- Provided chromatogramselectropherograms sometimes providing only

one lot instead of three lots

Result Success

Conclusions

Understanding analytical methods including real time

assessments of variability are becoming increasingly

important

The trends toward increased globalization will create

additional work and challenge for analytical professionals

Global Emerging Markets will become a larger portion of

the work due to increasing complexity in these markets

Acknowledgements

Catherine Anderson

Helena Madden

Sue Stella

Guidance list (non-inclusive) Region Topic ASEAN ASEAN GUIDELINE ON SUBMISSION OF MANUFACTURING PROCESS VALIDATION DATA FOR DRUG REGISTRATION

httpwwwhsagovsgpublishetcmedialibhsa_libraryhealth_products_regulationwestern_medicinesfiles_guidelinesPar96657FiledatA

SEAN20PV20(Version2031)20Main20Guide20without20annexespdf ASEAN VARIATION GUIDELINE FOR PHARMACEUTICAL PRODUCTS

httpwwwfdagovphattachmentsarticle95567ASEAN20Variation20Guideline20for20Pharmaceutical20Products20Final20

Draft207220(2013)pdf Thailand QampA on ASEAN Analytical Validation

httpwwwhsagovsgpublishetcmedialibhsa_libraryhealth_products_regulationwestern_medicinesfiles_guidelinesPar98887FiledatQ

ampA20analytical20validation-25jun55pdf ASEAN website with links to several guidances

httpwwwaseanorgcommunitiesasean-economic-communityitemharmonization-of-standards-and-technical-requirements-in-asean Brazil Resolution RDC No 27

httpwwwemergogroupcomfilesbrazil-resolution-rdc-no-27-21-june-2011pdf

Establishes Minimum Requirements for the Validation of Bioanalytical Methods Used in Pre- and Post-Marketing Studies

The validation of the analytical methods (Resolution RE 899 (IDRAC 39212) of 29-May-20033 and Resolution RDC 27 (IDRAC 143541) of

17-May-2012) is mandatory whenever the method is an in-house method or it is not described in pharmacopeias accepted by ANVISA Resolution RDC No 17

httpwwwabiquifiorgbrlegislacaoanvisaingles_rdc17pdf

16-Apr-2010 presents detailed guidelines about the validation and qualification requirements in the pharmaceutical industry as part of the

Good Manufacturing Practices Regulation Australia Note for Guidance on Validation of Analytical Procedures Text and Methodology

CPMPICH38195 (pdf183kb)

Japan Excerpt from presentation Japan has no guidance for bioanalytical method validation The answers in these slides are the results of the

discussion in the JBF kickoff meeting on March 30 (2011)1048579

httpwwwnihsgojpdrugBMVMontreal20110414_katoripdf Malaysia httpportalbpfkgovmyaeimagesFileAnalytical_Validation_Documents_of_Injections_Submission_Guidelinespdf Singapore ANALYTICAL METHOD VALIDATION

httpwwwhsagovsgpublishetcmedialibhsa_libraryhealth_products_regulationgmpfiles_1Par23186FiledatGUIDE-MQA-012A-

004pdf

Page 24: Capillary Electrophoresis in Global Emerging Markets: …c.ymcdn.com/sites/casss.site-ym.com/resource/resmgr/CE_Pharm...manufacturing process, ... From ASEAN Guideline on Analytical

GEM Requirements (examples) ASEAN Variation Guideline for Pharmaceutical

Products

Major Variation

- No analytical examples (not counting specification changes)

Minor Variation - Prior Approval (MiV-PA)

- Change of test procedure to non-compendial drug substance (must at

least show equivalence to former procedure) ndash MiV-PA9

- Change of in-process controls applied during the manufacture of the drug

substance (including tightening and addition of new in-process test) ndash MiV-

PA6

- Change of in-process controls applied during the manufacture of the drug

product (including tightening and addition of new in-process test) ndash MiV-

PA19

bull Interesting note Any new test method does not concern a novel non-standard

technique or a standard technique used in a novel way

Minor Variation - Notification (MiV-N)

- No analytical examples

24

GEM Requirements (examples) South Africa (Amendments)

Four categories

- Type A - amendments that may be implemented without intervention of or prior

notification to Council

- Type B - amendments that require prior notification

- Type C - amendments that require prior approval

- Type D - amendments that should be considered new applications

Type A Biological examples

- (25) Addition of release tests and or of specifications or tightening of

specifications for intermediates of the APIs

Type B Biological examples

- No analytical examples

25

GEM Requirements (examples) South Africa (Amendments)

Type C Biological examples

- (19B) Any change in analytical methods that

bull results in change(s) of specification limits or modification(s) in potency

sensitivity specificity or purity

bull establishes a new analytical method

bull deletes a specification or an analytical method

bull eliminates tests from the stability protocol or

bull alters the acceptance criteria of the stability protocol

- (20B) Any change in production processes that may

bull result in change(s) of specification limits or modification(s) in potency

sensitivity specificity or purity

bull establish a new analytical method

bull delete a specification or an analytical method

bull eliminate tests from the stability protocol or

bull alter the acceptance criteria of the stability protocol

26

Analytical Validation and Method Detail

(several)

Question Asked a series of questions on method details

requested method validation data for all methods used in

the analytical control strategy

Answer

- Provided copies of the methods and answered the specific

detail questions requested

- Some requests have included providing raw data (eg real

weight of reference standard and sample used) from validation

- This detail is requested as a substitute for in-country testing

thus preventing the need for in-country (repeat) testing

- The procedures are not considered ldquopart of the licenserdquo

Result Success

Method detail (South Korea)

Question Detailed test methods for API

Answer

- Provided descriptions of the assays but not copies of the methods

- These are not considered ldquopart of the licenserdquo (eg The detailed test

methods for Drug Substance are supplied as a reference The

information provided in Module 3 Section 32S42 Analytical

Procedures is considered to contain the regulatory information and

requirements)

Result Success

Detailed data (several)

Question Provide chromatograms and electropherograms for all

stability timepoints

Answer

- Provided chromatogramselectropherograms sometimes providing only

one lot instead of three lots

Result Success

Conclusions

Understanding analytical methods including real time

assessments of variability are becoming increasingly

important

The trends toward increased globalization will create

additional work and challenge for analytical professionals

Global Emerging Markets will become a larger portion of

the work due to increasing complexity in these markets

Acknowledgements

Catherine Anderson

Helena Madden

Sue Stella

Guidance list (non-inclusive) Region Topic ASEAN ASEAN GUIDELINE ON SUBMISSION OF MANUFACTURING PROCESS VALIDATION DATA FOR DRUG REGISTRATION

httpwwwhsagovsgpublishetcmedialibhsa_libraryhealth_products_regulationwestern_medicinesfiles_guidelinesPar96657FiledatA

SEAN20PV20(Version2031)20Main20Guide20without20annexespdf ASEAN VARIATION GUIDELINE FOR PHARMACEUTICAL PRODUCTS

httpwwwfdagovphattachmentsarticle95567ASEAN20Variation20Guideline20for20Pharmaceutical20Products20Final20

Draft207220(2013)pdf Thailand QampA on ASEAN Analytical Validation

httpwwwhsagovsgpublishetcmedialibhsa_libraryhealth_products_regulationwestern_medicinesfiles_guidelinesPar98887FiledatQ

ampA20analytical20validation-25jun55pdf ASEAN website with links to several guidances

httpwwwaseanorgcommunitiesasean-economic-communityitemharmonization-of-standards-and-technical-requirements-in-asean Brazil Resolution RDC No 27

httpwwwemergogroupcomfilesbrazil-resolution-rdc-no-27-21-june-2011pdf

Establishes Minimum Requirements for the Validation of Bioanalytical Methods Used in Pre- and Post-Marketing Studies

The validation of the analytical methods (Resolution RE 899 (IDRAC 39212) of 29-May-20033 and Resolution RDC 27 (IDRAC 143541) of

17-May-2012) is mandatory whenever the method is an in-house method or it is not described in pharmacopeias accepted by ANVISA Resolution RDC No 17

httpwwwabiquifiorgbrlegislacaoanvisaingles_rdc17pdf

16-Apr-2010 presents detailed guidelines about the validation and qualification requirements in the pharmaceutical industry as part of the

Good Manufacturing Practices Regulation Australia Note for Guidance on Validation of Analytical Procedures Text and Methodology

CPMPICH38195 (pdf183kb)

Japan Excerpt from presentation Japan has no guidance for bioanalytical method validation The answers in these slides are the results of the

discussion in the JBF kickoff meeting on March 30 (2011)1048579

httpwwwnihsgojpdrugBMVMontreal20110414_katoripdf Malaysia httpportalbpfkgovmyaeimagesFileAnalytical_Validation_Documents_of_Injections_Submission_Guidelinespdf Singapore ANALYTICAL METHOD VALIDATION

httpwwwhsagovsgpublishetcmedialibhsa_libraryhealth_products_regulationgmpfiles_1Par23186FiledatGUIDE-MQA-012A-

004pdf

Page 25: Capillary Electrophoresis in Global Emerging Markets: …c.ymcdn.com/sites/casss.site-ym.com/resource/resmgr/CE_Pharm...manufacturing process, ... From ASEAN Guideline on Analytical

GEM Requirements (examples) South Africa (Amendments)

Four categories

- Type A - amendments that may be implemented without intervention of or prior

notification to Council

- Type B - amendments that require prior notification

- Type C - amendments that require prior approval

- Type D - amendments that should be considered new applications

Type A Biological examples

- (25) Addition of release tests and or of specifications or tightening of

specifications for intermediates of the APIs

Type B Biological examples

- No analytical examples

25

GEM Requirements (examples) South Africa (Amendments)

Type C Biological examples

- (19B) Any change in analytical methods that

bull results in change(s) of specification limits or modification(s) in potency

sensitivity specificity or purity

bull establishes a new analytical method

bull deletes a specification or an analytical method

bull eliminates tests from the stability protocol or

bull alters the acceptance criteria of the stability protocol

- (20B) Any change in production processes that may

bull result in change(s) of specification limits or modification(s) in potency

sensitivity specificity or purity

bull establish a new analytical method

bull delete a specification or an analytical method

bull eliminate tests from the stability protocol or

bull alter the acceptance criteria of the stability protocol

26

Analytical Validation and Method Detail

(several)

Question Asked a series of questions on method details

requested method validation data for all methods used in

the analytical control strategy

Answer

- Provided copies of the methods and answered the specific

detail questions requested

- Some requests have included providing raw data (eg real

weight of reference standard and sample used) from validation

- This detail is requested as a substitute for in-country testing

thus preventing the need for in-country (repeat) testing

- The procedures are not considered ldquopart of the licenserdquo

Result Success

Method detail (South Korea)

Question Detailed test methods for API

Answer

- Provided descriptions of the assays but not copies of the methods

- These are not considered ldquopart of the licenserdquo (eg The detailed test

methods for Drug Substance are supplied as a reference The

information provided in Module 3 Section 32S42 Analytical

Procedures is considered to contain the regulatory information and

requirements)

Result Success

Detailed data (several)

Question Provide chromatograms and electropherograms for all

stability timepoints

Answer

- Provided chromatogramselectropherograms sometimes providing only

one lot instead of three lots

Result Success

Conclusions

Understanding analytical methods including real time

assessments of variability are becoming increasingly

important

The trends toward increased globalization will create

additional work and challenge for analytical professionals

Global Emerging Markets will become a larger portion of

the work due to increasing complexity in these markets

Acknowledgements

Catherine Anderson

Helena Madden

Sue Stella

Guidance list (non-inclusive) Region Topic ASEAN ASEAN GUIDELINE ON SUBMISSION OF MANUFACTURING PROCESS VALIDATION DATA FOR DRUG REGISTRATION

httpwwwhsagovsgpublishetcmedialibhsa_libraryhealth_products_regulationwestern_medicinesfiles_guidelinesPar96657FiledatA

SEAN20PV20(Version2031)20Main20Guide20without20annexespdf ASEAN VARIATION GUIDELINE FOR PHARMACEUTICAL PRODUCTS

httpwwwfdagovphattachmentsarticle95567ASEAN20Variation20Guideline20for20Pharmaceutical20Products20Final20

Draft207220(2013)pdf Thailand QampA on ASEAN Analytical Validation

httpwwwhsagovsgpublishetcmedialibhsa_libraryhealth_products_regulationwestern_medicinesfiles_guidelinesPar98887FiledatQ

ampA20analytical20validation-25jun55pdf ASEAN website with links to several guidances

httpwwwaseanorgcommunitiesasean-economic-communityitemharmonization-of-standards-and-technical-requirements-in-asean Brazil Resolution RDC No 27

httpwwwemergogroupcomfilesbrazil-resolution-rdc-no-27-21-june-2011pdf

Establishes Minimum Requirements for the Validation of Bioanalytical Methods Used in Pre- and Post-Marketing Studies

The validation of the analytical methods (Resolution RE 899 (IDRAC 39212) of 29-May-20033 and Resolution RDC 27 (IDRAC 143541) of

17-May-2012) is mandatory whenever the method is an in-house method or it is not described in pharmacopeias accepted by ANVISA Resolution RDC No 17

httpwwwabiquifiorgbrlegislacaoanvisaingles_rdc17pdf

16-Apr-2010 presents detailed guidelines about the validation and qualification requirements in the pharmaceutical industry as part of the

Good Manufacturing Practices Regulation Australia Note for Guidance on Validation of Analytical Procedures Text and Methodology

CPMPICH38195 (pdf183kb)

Japan Excerpt from presentation Japan has no guidance for bioanalytical method validation The answers in these slides are the results of the

discussion in the JBF kickoff meeting on March 30 (2011)1048579

httpwwwnihsgojpdrugBMVMontreal20110414_katoripdf Malaysia httpportalbpfkgovmyaeimagesFileAnalytical_Validation_Documents_of_Injections_Submission_Guidelinespdf Singapore ANALYTICAL METHOD VALIDATION

httpwwwhsagovsgpublishetcmedialibhsa_libraryhealth_products_regulationgmpfiles_1Par23186FiledatGUIDE-MQA-012A-

004pdf

Page 26: Capillary Electrophoresis in Global Emerging Markets: …c.ymcdn.com/sites/casss.site-ym.com/resource/resmgr/CE_Pharm...manufacturing process, ... From ASEAN Guideline on Analytical

GEM Requirements (examples) South Africa (Amendments)

Type C Biological examples

- (19B) Any change in analytical methods that

bull results in change(s) of specification limits or modification(s) in potency

sensitivity specificity or purity

bull establishes a new analytical method

bull deletes a specification or an analytical method

bull eliminates tests from the stability protocol or

bull alters the acceptance criteria of the stability protocol

- (20B) Any change in production processes that may

bull result in change(s) of specification limits or modification(s) in potency

sensitivity specificity or purity

bull establish a new analytical method

bull delete a specification or an analytical method

bull eliminate tests from the stability protocol or

bull alter the acceptance criteria of the stability protocol

26

Analytical Validation and Method Detail

(several)

Question Asked a series of questions on method details

requested method validation data for all methods used in

the analytical control strategy

Answer

- Provided copies of the methods and answered the specific

detail questions requested

- Some requests have included providing raw data (eg real

weight of reference standard and sample used) from validation

- This detail is requested as a substitute for in-country testing

thus preventing the need for in-country (repeat) testing

- The procedures are not considered ldquopart of the licenserdquo

Result Success

Method detail (South Korea)

Question Detailed test methods for API

Answer

- Provided descriptions of the assays but not copies of the methods

- These are not considered ldquopart of the licenserdquo (eg The detailed test

methods for Drug Substance are supplied as a reference The

information provided in Module 3 Section 32S42 Analytical

Procedures is considered to contain the regulatory information and

requirements)

Result Success

Detailed data (several)

Question Provide chromatograms and electropherograms for all

stability timepoints

Answer

- Provided chromatogramselectropherograms sometimes providing only

one lot instead of three lots

Result Success

Conclusions

Understanding analytical methods including real time

assessments of variability are becoming increasingly

important

The trends toward increased globalization will create

additional work and challenge for analytical professionals

Global Emerging Markets will become a larger portion of

the work due to increasing complexity in these markets

Acknowledgements

Catherine Anderson

Helena Madden

Sue Stella

Guidance list (non-inclusive) Region Topic ASEAN ASEAN GUIDELINE ON SUBMISSION OF MANUFACTURING PROCESS VALIDATION DATA FOR DRUG REGISTRATION

httpwwwhsagovsgpublishetcmedialibhsa_libraryhealth_products_regulationwestern_medicinesfiles_guidelinesPar96657FiledatA

SEAN20PV20(Version2031)20Main20Guide20without20annexespdf ASEAN VARIATION GUIDELINE FOR PHARMACEUTICAL PRODUCTS

httpwwwfdagovphattachmentsarticle95567ASEAN20Variation20Guideline20for20Pharmaceutical20Products20Final20

Draft207220(2013)pdf Thailand QampA on ASEAN Analytical Validation

httpwwwhsagovsgpublishetcmedialibhsa_libraryhealth_products_regulationwestern_medicinesfiles_guidelinesPar98887FiledatQ

ampA20analytical20validation-25jun55pdf ASEAN website with links to several guidances

httpwwwaseanorgcommunitiesasean-economic-communityitemharmonization-of-standards-and-technical-requirements-in-asean Brazil Resolution RDC No 27

httpwwwemergogroupcomfilesbrazil-resolution-rdc-no-27-21-june-2011pdf

Establishes Minimum Requirements for the Validation of Bioanalytical Methods Used in Pre- and Post-Marketing Studies

The validation of the analytical methods (Resolution RE 899 (IDRAC 39212) of 29-May-20033 and Resolution RDC 27 (IDRAC 143541) of

17-May-2012) is mandatory whenever the method is an in-house method or it is not described in pharmacopeias accepted by ANVISA Resolution RDC No 17

httpwwwabiquifiorgbrlegislacaoanvisaingles_rdc17pdf

16-Apr-2010 presents detailed guidelines about the validation and qualification requirements in the pharmaceutical industry as part of the

Good Manufacturing Practices Regulation Australia Note for Guidance on Validation of Analytical Procedures Text and Methodology

CPMPICH38195 (pdf183kb)

Japan Excerpt from presentation Japan has no guidance for bioanalytical method validation The answers in these slides are the results of the

discussion in the JBF kickoff meeting on March 30 (2011)1048579

httpwwwnihsgojpdrugBMVMontreal20110414_katoripdf Malaysia httpportalbpfkgovmyaeimagesFileAnalytical_Validation_Documents_of_Injections_Submission_Guidelinespdf Singapore ANALYTICAL METHOD VALIDATION

httpwwwhsagovsgpublishetcmedialibhsa_libraryhealth_products_regulationgmpfiles_1Par23186FiledatGUIDE-MQA-012A-

004pdf

Page 27: Capillary Electrophoresis in Global Emerging Markets: …c.ymcdn.com/sites/casss.site-ym.com/resource/resmgr/CE_Pharm...manufacturing process, ... From ASEAN Guideline on Analytical

Analytical Validation and Method Detail

(several)

Question Asked a series of questions on method details

requested method validation data for all methods used in

the analytical control strategy

Answer

- Provided copies of the methods and answered the specific

detail questions requested

- Some requests have included providing raw data (eg real

weight of reference standard and sample used) from validation

- This detail is requested as a substitute for in-country testing

thus preventing the need for in-country (repeat) testing

- The procedures are not considered ldquopart of the licenserdquo

Result Success

Method detail (South Korea)

Question Detailed test methods for API

Answer

- Provided descriptions of the assays but not copies of the methods

- These are not considered ldquopart of the licenserdquo (eg The detailed test

methods for Drug Substance are supplied as a reference The

information provided in Module 3 Section 32S42 Analytical

Procedures is considered to contain the regulatory information and

requirements)

Result Success

Detailed data (several)

Question Provide chromatograms and electropherograms for all

stability timepoints

Answer

- Provided chromatogramselectropherograms sometimes providing only

one lot instead of three lots

Result Success

Conclusions

Understanding analytical methods including real time

assessments of variability are becoming increasingly

important

The trends toward increased globalization will create

additional work and challenge for analytical professionals

Global Emerging Markets will become a larger portion of

the work due to increasing complexity in these markets

Acknowledgements

Catherine Anderson

Helena Madden

Sue Stella

Guidance list (non-inclusive) Region Topic ASEAN ASEAN GUIDELINE ON SUBMISSION OF MANUFACTURING PROCESS VALIDATION DATA FOR DRUG REGISTRATION

httpwwwhsagovsgpublishetcmedialibhsa_libraryhealth_products_regulationwestern_medicinesfiles_guidelinesPar96657FiledatA

SEAN20PV20(Version2031)20Main20Guide20without20annexespdf ASEAN VARIATION GUIDELINE FOR PHARMACEUTICAL PRODUCTS

httpwwwfdagovphattachmentsarticle95567ASEAN20Variation20Guideline20for20Pharmaceutical20Products20Final20

Draft207220(2013)pdf Thailand QampA on ASEAN Analytical Validation

httpwwwhsagovsgpublishetcmedialibhsa_libraryhealth_products_regulationwestern_medicinesfiles_guidelinesPar98887FiledatQ

ampA20analytical20validation-25jun55pdf ASEAN website with links to several guidances

httpwwwaseanorgcommunitiesasean-economic-communityitemharmonization-of-standards-and-technical-requirements-in-asean Brazil Resolution RDC No 27

httpwwwemergogroupcomfilesbrazil-resolution-rdc-no-27-21-june-2011pdf

Establishes Minimum Requirements for the Validation of Bioanalytical Methods Used in Pre- and Post-Marketing Studies

The validation of the analytical methods (Resolution RE 899 (IDRAC 39212) of 29-May-20033 and Resolution RDC 27 (IDRAC 143541) of

17-May-2012) is mandatory whenever the method is an in-house method or it is not described in pharmacopeias accepted by ANVISA Resolution RDC No 17

httpwwwabiquifiorgbrlegislacaoanvisaingles_rdc17pdf

16-Apr-2010 presents detailed guidelines about the validation and qualification requirements in the pharmaceutical industry as part of the

Good Manufacturing Practices Regulation Australia Note for Guidance on Validation of Analytical Procedures Text and Methodology

CPMPICH38195 (pdf183kb)

Japan Excerpt from presentation Japan has no guidance for bioanalytical method validation The answers in these slides are the results of the

discussion in the JBF kickoff meeting on March 30 (2011)1048579

httpwwwnihsgojpdrugBMVMontreal20110414_katoripdf Malaysia httpportalbpfkgovmyaeimagesFileAnalytical_Validation_Documents_of_Injections_Submission_Guidelinespdf Singapore ANALYTICAL METHOD VALIDATION

httpwwwhsagovsgpublishetcmedialibhsa_libraryhealth_products_regulationgmpfiles_1Par23186FiledatGUIDE-MQA-012A-

004pdf

Page 28: Capillary Electrophoresis in Global Emerging Markets: …c.ymcdn.com/sites/casss.site-ym.com/resource/resmgr/CE_Pharm...manufacturing process, ... From ASEAN Guideline on Analytical

Method detail (South Korea)

Question Detailed test methods for API

Answer

- Provided descriptions of the assays but not copies of the methods

- These are not considered ldquopart of the licenserdquo (eg The detailed test

methods for Drug Substance are supplied as a reference The

information provided in Module 3 Section 32S42 Analytical

Procedures is considered to contain the regulatory information and

requirements)

Result Success

Detailed data (several)

Question Provide chromatograms and electropherograms for all

stability timepoints

Answer

- Provided chromatogramselectropherograms sometimes providing only

one lot instead of three lots

Result Success

Conclusions

Understanding analytical methods including real time

assessments of variability are becoming increasingly

important

The trends toward increased globalization will create

additional work and challenge for analytical professionals

Global Emerging Markets will become a larger portion of

the work due to increasing complexity in these markets

Acknowledgements

Catherine Anderson

Helena Madden

Sue Stella

Guidance list (non-inclusive) Region Topic ASEAN ASEAN GUIDELINE ON SUBMISSION OF MANUFACTURING PROCESS VALIDATION DATA FOR DRUG REGISTRATION

httpwwwhsagovsgpublishetcmedialibhsa_libraryhealth_products_regulationwestern_medicinesfiles_guidelinesPar96657FiledatA

SEAN20PV20(Version2031)20Main20Guide20without20annexespdf ASEAN VARIATION GUIDELINE FOR PHARMACEUTICAL PRODUCTS

httpwwwfdagovphattachmentsarticle95567ASEAN20Variation20Guideline20for20Pharmaceutical20Products20Final20

Draft207220(2013)pdf Thailand QampA on ASEAN Analytical Validation

httpwwwhsagovsgpublishetcmedialibhsa_libraryhealth_products_regulationwestern_medicinesfiles_guidelinesPar98887FiledatQ

ampA20analytical20validation-25jun55pdf ASEAN website with links to several guidances

httpwwwaseanorgcommunitiesasean-economic-communityitemharmonization-of-standards-and-technical-requirements-in-asean Brazil Resolution RDC No 27

httpwwwemergogroupcomfilesbrazil-resolution-rdc-no-27-21-june-2011pdf

Establishes Minimum Requirements for the Validation of Bioanalytical Methods Used in Pre- and Post-Marketing Studies

The validation of the analytical methods (Resolution RE 899 (IDRAC 39212) of 29-May-20033 and Resolution RDC 27 (IDRAC 143541) of

17-May-2012) is mandatory whenever the method is an in-house method or it is not described in pharmacopeias accepted by ANVISA Resolution RDC No 17

httpwwwabiquifiorgbrlegislacaoanvisaingles_rdc17pdf

16-Apr-2010 presents detailed guidelines about the validation and qualification requirements in the pharmaceutical industry as part of the

Good Manufacturing Practices Regulation Australia Note for Guidance on Validation of Analytical Procedures Text and Methodology

CPMPICH38195 (pdf183kb)

Japan Excerpt from presentation Japan has no guidance for bioanalytical method validation The answers in these slides are the results of the

discussion in the JBF kickoff meeting on March 30 (2011)1048579

httpwwwnihsgojpdrugBMVMontreal20110414_katoripdf Malaysia httpportalbpfkgovmyaeimagesFileAnalytical_Validation_Documents_of_Injections_Submission_Guidelinespdf Singapore ANALYTICAL METHOD VALIDATION

httpwwwhsagovsgpublishetcmedialibhsa_libraryhealth_products_regulationgmpfiles_1Par23186FiledatGUIDE-MQA-012A-

004pdf

Page 29: Capillary Electrophoresis in Global Emerging Markets: …c.ymcdn.com/sites/casss.site-ym.com/resource/resmgr/CE_Pharm...manufacturing process, ... From ASEAN Guideline on Analytical

Detailed data (several)

Question Provide chromatograms and electropherograms for all

stability timepoints

Answer

- Provided chromatogramselectropherograms sometimes providing only

one lot instead of three lots

Result Success

Conclusions

Understanding analytical methods including real time

assessments of variability are becoming increasingly

important

The trends toward increased globalization will create

additional work and challenge for analytical professionals

Global Emerging Markets will become a larger portion of

the work due to increasing complexity in these markets

Acknowledgements

Catherine Anderson

Helena Madden

Sue Stella

Guidance list (non-inclusive) Region Topic ASEAN ASEAN GUIDELINE ON SUBMISSION OF MANUFACTURING PROCESS VALIDATION DATA FOR DRUG REGISTRATION

httpwwwhsagovsgpublishetcmedialibhsa_libraryhealth_products_regulationwestern_medicinesfiles_guidelinesPar96657FiledatA

SEAN20PV20(Version2031)20Main20Guide20without20annexespdf ASEAN VARIATION GUIDELINE FOR PHARMACEUTICAL PRODUCTS

httpwwwfdagovphattachmentsarticle95567ASEAN20Variation20Guideline20for20Pharmaceutical20Products20Final20

Draft207220(2013)pdf Thailand QampA on ASEAN Analytical Validation

httpwwwhsagovsgpublishetcmedialibhsa_libraryhealth_products_regulationwestern_medicinesfiles_guidelinesPar98887FiledatQ

ampA20analytical20validation-25jun55pdf ASEAN website with links to several guidances

httpwwwaseanorgcommunitiesasean-economic-communityitemharmonization-of-standards-and-technical-requirements-in-asean Brazil Resolution RDC No 27

httpwwwemergogroupcomfilesbrazil-resolution-rdc-no-27-21-june-2011pdf

Establishes Minimum Requirements for the Validation of Bioanalytical Methods Used in Pre- and Post-Marketing Studies

The validation of the analytical methods (Resolution RE 899 (IDRAC 39212) of 29-May-20033 and Resolution RDC 27 (IDRAC 143541) of

17-May-2012) is mandatory whenever the method is an in-house method or it is not described in pharmacopeias accepted by ANVISA Resolution RDC No 17

httpwwwabiquifiorgbrlegislacaoanvisaingles_rdc17pdf

16-Apr-2010 presents detailed guidelines about the validation and qualification requirements in the pharmaceutical industry as part of the

Good Manufacturing Practices Regulation Australia Note for Guidance on Validation of Analytical Procedures Text and Methodology

CPMPICH38195 (pdf183kb)

Japan Excerpt from presentation Japan has no guidance for bioanalytical method validation The answers in these slides are the results of the

discussion in the JBF kickoff meeting on March 30 (2011)1048579

httpwwwnihsgojpdrugBMVMontreal20110414_katoripdf Malaysia httpportalbpfkgovmyaeimagesFileAnalytical_Validation_Documents_of_Injections_Submission_Guidelinespdf Singapore ANALYTICAL METHOD VALIDATION

httpwwwhsagovsgpublishetcmedialibhsa_libraryhealth_products_regulationgmpfiles_1Par23186FiledatGUIDE-MQA-012A-

004pdf

Page 30: Capillary Electrophoresis in Global Emerging Markets: …c.ymcdn.com/sites/casss.site-ym.com/resource/resmgr/CE_Pharm...manufacturing process, ... From ASEAN Guideline on Analytical

Conclusions

Understanding analytical methods including real time

assessments of variability are becoming increasingly

important

The trends toward increased globalization will create

additional work and challenge for analytical professionals

Global Emerging Markets will become a larger portion of

the work due to increasing complexity in these markets

Acknowledgements

Catherine Anderson

Helena Madden

Sue Stella

Guidance list (non-inclusive) Region Topic ASEAN ASEAN GUIDELINE ON SUBMISSION OF MANUFACTURING PROCESS VALIDATION DATA FOR DRUG REGISTRATION

httpwwwhsagovsgpublishetcmedialibhsa_libraryhealth_products_regulationwestern_medicinesfiles_guidelinesPar96657FiledatA

SEAN20PV20(Version2031)20Main20Guide20without20annexespdf ASEAN VARIATION GUIDELINE FOR PHARMACEUTICAL PRODUCTS

httpwwwfdagovphattachmentsarticle95567ASEAN20Variation20Guideline20for20Pharmaceutical20Products20Final20

Draft207220(2013)pdf Thailand QampA on ASEAN Analytical Validation

httpwwwhsagovsgpublishetcmedialibhsa_libraryhealth_products_regulationwestern_medicinesfiles_guidelinesPar98887FiledatQ

ampA20analytical20validation-25jun55pdf ASEAN website with links to several guidances

httpwwwaseanorgcommunitiesasean-economic-communityitemharmonization-of-standards-and-technical-requirements-in-asean Brazil Resolution RDC No 27

httpwwwemergogroupcomfilesbrazil-resolution-rdc-no-27-21-june-2011pdf

Establishes Minimum Requirements for the Validation of Bioanalytical Methods Used in Pre- and Post-Marketing Studies

The validation of the analytical methods (Resolution RE 899 (IDRAC 39212) of 29-May-20033 and Resolution RDC 27 (IDRAC 143541) of

17-May-2012) is mandatory whenever the method is an in-house method or it is not described in pharmacopeias accepted by ANVISA Resolution RDC No 17

httpwwwabiquifiorgbrlegislacaoanvisaingles_rdc17pdf

16-Apr-2010 presents detailed guidelines about the validation and qualification requirements in the pharmaceutical industry as part of the

Good Manufacturing Practices Regulation Australia Note for Guidance on Validation of Analytical Procedures Text and Methodology

CPMPICH38195 (pdf183kb)

Japan Excerpt from presentation Japan has no guidance for bioanalytical method validation The answers in these slides are the results of the

discussion in the JBF kickoff meeting on March 30 (2011)1048579

httpwwwnihsgojpdrugBMVMontreal20110414_katoripdf Malaysia httpportalbpfkgovmyaeimagesFileAnalytical_Validation_Documents_of_Injections_Submission_Guidelinespdf Singapore ANALYTICAL METHOD VALIDATION

httpwwwhsagovsgpublishetcmedialibhsa_libraryhealth_products_regulationgmpfiles_1Par23186FiledatGUIDE-MQA-012A-

004pdf

Page 31: Capillary Electrophoresis in Global Emerging Markets: …c.ymcdn.com/sites/casss.site-ym.com/resource/resmgr/CE_Pharm...manufacturing process, ... From ASEAN Guideline on Analytical

Acknowledgements

Catherine Anderson

Helena Madden

Sue Stella

Guidance list (non-inclusive) Region Topic ASEAN ASEAN GUIDELINE ON SUBMISSION OF MANUFACTURING PROCESS VALIDATION DATA FOR DRUG REGISTRATION

httpwwwhsagovsgpublishetcmedialibhsa_libraryhealth_products_regulationwestern_medicinesfiles_guidelinesPar96657FiledatA

SEAN20PV20(Version2031)20Main20Guide20without20annexespdf ASEAN VARIATION GUIDELINE FOR PHARMACEUTICAL PRODUCTS

httpwwwfdagovphattachmentsarticle95567ASEAN20Variation20Guideline20for20Pharmaceutical20Products20Final20

Draft207220(2013)pdf Thailand QampA on ASEAN Analytical Validation

httpwwwhsagovsgpublishetcmedialibhsa_libraryhealth_products_regulationwestern_medicinesfiles_guidelinesPar98887FiledatQ

ampA20analytical20validation-25jun55pdf ASEAN website with links to several guidances

httpwwwaseanorgcommunitiesasean-economic-communityitemharmonization-of-standards-and-technical-requirements-in-asean Brazil Resolution RDC No 27

httpwwwemergogroupcomfilesbrazil-resolution-rdc-no-27-21-june-2011pdf

Establishes Minimum Requirements for the Validation of Bioanalytical Methods Used in Pre- and Post-Marketing Studies

The validation of the analytical methods (Resolution RE 899 (IDRAC 39212) of 29-May-20033 and Resolution RDC 27 (IDRAC 143541) of

17-May-2012) is mandatory whenever the method is an in-house method or it is not described in pharmacopeias accepted by ANVISA Resolution RDC No 17

httpwwwabiquifiorgbrlegislacaoanvisaingles_rdc17pdf

16-Apr-2010 presents detailed guidelines about the validation and qualification requirements in the pharmaceutical industry as part of the

Good Manufacturing Practices Regulation Australia Note for Guidance on Validation of Analytical Procedures Text and Methodology

CPMPICH38195 (pdf183kb)

Japan Excerpt from presentation Japan has no guidance for bioanalytical method validation The answers in these slides are the results of the

discussion in the JBF kickoff meeting on March 30 (2011)1048579

httpwwwnihsgojpdrugBMVMontreal20110414_katoripdf Malaysia httpportalbpfkgovmyaeimagesFileAnalytical_Validation_Documents_of_Injections_Submission_Guidelinespdf Singapore ANALYTICAL METHOD VALIDATION

httpwwwhsagovsgpublishetcmedialibhsa_libraryhealth_products_regulationgmpfiles_1Par23186FiledatGUIDE-MQA-012A-

004pdf

Page 32: Capillary Electrophoresis in Global Emerging Markets: …c.ymcdn.com/sites/casss.site-ym.com/resource/resmgr/CE_Pharm...manufacturing process, ... From ASEAN Guideline on Analytical

Guidance list (non-inclusive) Region Topic ASEAN ASEAN GUIDELINE ON SUBMISSION OF MANUFACTURING PROCESS VALIDATION DATA FOR DRUG REGISTRATION

httpwwwhsagovsgpublishetcmedialibhsa_libraryhealth_products_regulationwestern_medicinesfiles_guidelinesPar96657FiledatA

SEAN20PV20(Version2031)20Main20Guide20without20annexespdf ASEAN VARIATION GUIDELINE FOR PHARMACEUTICAL PRODUCTS

httpwwwfdagovphattachmentsarticle95567ASEAN20Variation20Guideline20for20Pharmaceutical20Products20Final20

Draft207220(2013)pdf Thailand QampA on ASEAN Analytical Validation

httpwwwhsagovsgpublishetcmedialibhsa_libraryhealth_products_regulationwestern_medicinesfiles_guidelinesPar98887FiledatQ

ampA20analytical20validation-25jun55pdf ASEAN website with links to several guidances

httpwwwaseanorgcommunitiesasean-economic-communityitemharmonization-of-standards-and-technical-requirements-in-asean Brazil Resolution RDC No 27

httpwwwemergogroupcomfilesbrazil-resolution-rdc-no-27-21-june-2011pdf

Establishes Minimum Requirements for the Validation of Bioanalytical Methods Used in Pre- and Post-Marketing Studies

The validation of the analytical methods (Resolution RE 899 (IDRAC 39212) of 29-May-20033 and Resolution RDC 27 (IDRAC 143541) of

17-May-2012) is mandatory whenever the method is an in-house method or it is not described in pharmacopeias accepted by ANVISA Resolution RDC No 17

httpwwwabiquifiorgbrlegislacaoanvisaingles_rdc17pdf

16-Apr-2010 presents detailed guidelines about the validation and qualification requirements in the pharmaceutical industry as part of the

Good Manufacturing Practices Regulation Australia Note for Guidance on Validation of Analytical Procedures Text and Methodology

CPMPICH38195 (pdf183kb)

Japan Excerpt from presentation Japan has no guidance for bioanalytical method validation The answers in these slides are the results of the

discussion in the JBF kickoff meeting on March 30 (2011)1048579

httpwwwnihsgojpdrugBMVMontreal20110414_katoripdf Malaysia httpportalbpfkgovmyaeimagesFileAnalytical_Validation_Documents_of_Injections_Submission_Guidelinespdf Singapore ANALYTICAL METHOD VALIDATION

httpwwwhsagovsgpublishetcmedialibhsa_libraryhealth_products_regulationgmpfiles_1Par23186FiledatGUIDE-MQA-012A-

004pdf